Geofence Warrants at the Supreme Court: Chatrie Explained

The U.S. Supreme Court is weighing whether a geofence warrant, which forces Google to identify every device near a crime scene, violates the Fourth Amendment. In Chatrie v. United States (No. 25-112), the justices heard argument on April 27, 2026, but have not yet ruled.

Status: Argued before the U.S. Supreme Court on April 27, 2026 (No. 25-112). No decision had been issued as of June 19, 2026. This is a developing matter and remains undecided.

Information last verified on June 19, 2026. This is a developing story; we update it as the record changes.

Jurisdiction scope: This article addresses a federal Fourth Amendment case pending before the U.S. Supreme Court. It explains the law generally and does not advise on any specific investigation, prosecution, or motion. For related coverage, see GPS tracking laws by state and AI and data privacy.

What Is a Geofence Warrant

A geofence warrant (also called a reverse-location warrant) directs a technology company to identify the devices that were inside a defined geographic area during a defined time period, rather than naming a suspect in advance.

Unlike a traditional warrant that names a person or place, a geofence warrant starts with a location and works backward to find who was there. Investigators draw a map boundary and a time window, then order a provider to return data on every device the provider logged inside that box. In Chatrie, the request went to Google, which maintains location records for users who enabled its Location History setting.

The process typically moves in steps. The provider first returns an anonymized list of device identifiers and coordinates. Law enforcement then narrows that list and asks the provider to deanonymize a smaller set, ultimately producing account information tied to named individuals. Because the first step sweeps in everyone present, including uninvolved bystanders, courts have wrestled with whether the technique is a reasonable search or a digital dragnet.

What Happened in the Chatrie Case

The case arose from a 2019 armed robbery of a credit union in Virginia. Investigators obtained a geofence warrant directing Google to disclose anonymized Location History data for every device within roughly 150 meters of the robbery location during a one-hour window. After Google returned an initial list, officers sought expanded movement data for certain devices over a longer period and Google complied. That data helped identify Okello Chatrie as a suspect, and he was charged with federal offenses.

Chatrie moved to suppress the geofence evidence. The U.S. District Court for the Eastern District of Virginia denied the motion (590 F. Supp. 3d 901 (E.D. Va. 2022)). A panel of the Fourth Circuit affirmed (107 F.4th 319 (4th Cir. 2024)), and the full court affirmed again on rehearing en banc (136 F.4th 100 (4th Cir. 2025)).

The en banc result was unusually fractured. The court issued a one-sentence per curiam opinion affirming the denial of suppression, accompanied by many separate concurrences and dissents. The judges divided 7-7 on the threshold question of whether obtaining the data was a Fourth Amendment search at all, and the affirmance ultimately rested on the good-faith exception rather than a majority holding that no search occurred.

"Whether the execution of a geofence warrant violated the Fourth Amendment."

Question presented, Chatrie v. United States, No. 25-112

Chatrie petitioned the Supreme Court. The Court granted certiorari on January 16, 2026 and heard oral argument on April 27, 2026. As of June 19, 2026, no opinion has issued.

The Fourth Amendment and the Carpenter Line

The Fourth Amendment protects "the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures." For decades, the third-party doctrine held that a person generally has no reasonable expectation of privacy in information voluntarily shared with a third party, such as a phone company.

That framework shifted in Carpenter v. United States, 585 U.S. 296 (2018). The Court held that the government conducts a Fourth Amendment search when it accesses historical cell-site location information that maps a person's movements over time, even though a wireless carrier holds those records. Chief Justice Roberts wrote that "the fact that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Carpenter required a warrant supported by probable cause for that category of location data.

Geofence warrants raise the question Carpenter left open at its edges. The data here is held by a third party (Google) and reflects location over time, yet the technique begins with the location and identifies people only afterward. The Fourth and Fifth Circuits read the doctrine differently. The Fourth Circuit, in the rulings below, treated voluntarily enabled Location History as outside Fourth Amendment protection for at least part of the court. The Fifth Circuit, in United States v. Smith (5th Cir. 2024), held that geofence warrants operate as unconstitutional general warrants because they search everyone in an area without individualized probable cause. That conflict is the kind of circuit split the Supreme Court often takes up.

What Happens Next

The Supreme Court heard argument on April 27, 2026. By custom, the Court issues decisions in argued cases before its term concludes, so a ruling in Chatrie is expected by the end of the current term. Until the Court releases a signed opinion, the law on geofence warrants remains unsettled at the national level and continues to vary by circuit.

Several broad outcomes are possible, and we describe them in general terms without predicting which the Court will choose. The Court could hold that executing a geofence warrant is a Fourth Amendment search, which would generally require probable cause and particularity for the technique. It could hold that the conduct is not a search under existing doctrine, which would leave geofence requests outside the warrant requirement in most settings. It could resolve the case on narrower grounds, such as the good-faith exception the Fourth Circuit relied on, which would leave the core constitutional question for another day. Each path would change how investigators, providers, and lower courts treat reverse-location requests going forward.

The event that converts this explainer into settled law is the issuance of the Court's opinion. When that happens, the holding will control nationwide and supersede the conflicting circuit decisions described here.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

Chatrie is the first time the Supreme Court has squarely confronted geofence warrants, and the posture matters as much as the question. The Fourth Circuit affirmed without a majority on whether a search occurred, and the 7-7 split signals that experienced judges genuinely disagree about how Carpenter applies to data that starts anonymized and location-first. That disagreement, paired with the Fifth Circuit's contrary general-warrant analysis in Smith, is why the case reached the Court rather than resting on a clean rule below.

The stakes are practical and broad. Geofence requests have become a common investigative tool precisely because location data is abundant and centralized in a few providers. However the Court resolves the question, its reasoning will shape how the third-party doctrine survives in an era of continuous location logging, a theme that connects directly to the site's coverage of GPS tracking laws, biometric privacy laws, and AI and data privacy. A ruling that treats geofence data as a search would push investigators toward narrower, more particularized requests. A ruling the other way would leave reverse-location searches largely to statute and provider policy. We are not predicting which way the Court will go; we are flagging that the opinion, once issued, is likely to be a reference point for digital-location privacy for years.

How This Affects You

This section describes general implications, not advice about any specific situation. As of June 19, 2026, the constitutionality of geofence warrants is unresolved at the Supreme Court, and lower courts continue to apply their own circuit's rule. That means the legal treatment of a geofence request can differ depending on where a case arises. People who use location-aware apps generate the kind of records these warrants target, and whether that data is protected often turns on settings, provider practices, and the controlling court's reading of Carpenter. Anyone facing a specific legal question about location data in an investigation should consult a lawyer licensed in the relevant jurisdiction.

This is general legal information, not legal advice. It covers a federal Fourth Amendment case pending before the U.S. Supreme Court and reflects sources verified on June 19, 2026. Laws change and this matter is undecided; consult a lawyer licensed in your jurisdiction about your specific situation.

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Last updated: 2026-06-19. This is a developing story; details verified as of 2026-06-19.