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Supreme Court Rules Geofence Warrants Are a Fourth Amendment Search (Chatrie v. United States)

Independently fact-checkedBy Recording Law Editorial Team8 min read

Independently fact-checked against primary sources (last audited July 1, 2026). · 4 primary sources cited on this page. How we verify our legal content

Supreme Court Rules Geofence Warrants Are a Fourth Amendment Search (Chatrie v. United States)

Supreme Court Rules Geofence Warrants Are a Fourth Amendment Search (Chatrie v. United States)

The U.S. Supreme Court held on June 29, 2026 that police conduct a Fourth Amendment search when they use a geofence warrant to pull a person's cell-phone location data from Google. The 6-3 decision in Chatrie v. United States (No. 25-112) vacated the Fourth Circuit's judgment and sent the case back to decide whether the search was reasonable.

Information last verified on July 1, 2026. This is a developing story; we update it as the record changes.

Status: Decided by the U.S. Supreme Court on June 29, 2026 (No. 25-112), by a vote of 6-3. The Court held that a geofence warrant is a Fourth Amendment search and vacated and remanded to the Fourth Circuit. Whether this particular search was reasonable, and whether the good-faith exception saves the evidence, remain open on remand as of July 1, 2026.

Jurisdiction scope: This article addresses a federal Fourth Amendment holding that applies nationwide. It explains the ruling 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 Happened

On June 29, 2026, the Supreme Court decided Chatrie v. United States, No. 25-112, holding 6-3 that law enforcement conducted a Fourth Amendment search when it used a geofence warrant to obtain Okello Chatrie's cell-phone location data from Google. The case grew out of a May 2019 armed robbery of a credit union in Midlothian, Virginia. Investigators obtained a warrant directing Google to disclose Location History data for devices within roughly a 150-meter radius of the credit union during a set time window near the robbery. That data helped identify Chatrie, who was later convicted.

Justice Kagan delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, and Jackson. The majority framed the question around a person's privacy interest in the records that map where a phone has been.

"An individual has a reasonable expectation of privacy in records about his cell phone's location, and police intrude on that constitutionally protected interest when they demand the information, even though for only a limited time, and from a third-party tech company."

Justice Kagan, majority opinion, Chatrie v. United States, No. 25-112 (2026)

Justice Gorsuch concurred in the judgment, providing the sixth vote for the result but on a different theory. Rather than resting on privacy expectations, he reasoned that Chatrie's Location History is his personal property, one of the "effects" the Fourth Amendment names, and that entrusting data to Google no more forfeits ownership than handing car keys to a valet. Justice Alito filed a dissent, joined in part by Justices Thomas and Barrett, arguing that Chatrie voluntarily turned the information over to Google and that the government therefore needed no warrant.

Critically, the Court did not decide that the search here was unlawful. It vacated the judgment of the U.S. Court of Appeals for the Fourth Circuit and remanded the case. The reasonableness of the search, and whether the good-faith exception to the exclusionary rule permits the evidence to stand, are questions the Fourth Circuit will address anew.

police cruiser parked outside a courthouse, wide stone steps behind

What the Law Actually Says

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 bank or a phone company.

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

Chatrie carries that reasoning into the geofence context. A geofence warrant, also called a reverse-location warrant, starts with a place and a time rather than a named suspect. It orders a provider such as Google to identify the devices logged inside a drawn boundary during a window, then works from anonymized identifiers toward named account holders. The majority concluded that Carpenter's refusal to apply the third-party doctrine to sensitive location data governs Location History too, so the initial demand for that data is a search. The decision resolves a split that had developed after the Fifth Circuit, in United States v. Smith (5th Cir. 2024), treated geofence warrants as unconstitutional general warrants while the Fourth Circuit had upheld the evidence below. For how location tracking is regulated outside the warrant context, see the site's coverage of GPS tracking laws by state and biometric privacy laws.

smartphone showing location services settings on its screen

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

Chatrie is the first time the Supreme Court has squarely addressed geofence warrants, and the holding lands on the search side of the question that had divided lower courts. That matters because a search classification pulls geofence requests inside the Fourth Amendment's framework of probable cause and particularity, rather than leaving them to provider policy and local practice. The majority and the Gorsuch concurrence reach the same result through different doors: Kagan through the reasonable-expectation-of-privacy line that runs through Carpenter, and Gorsuch through a property-based reading of the word "effects." Both approaches reject the government's argument that sharing data with Google strips away constitutional protection.

The decision is consequential but deliberately incomplete. By vacating and remanding rather than suppressing the evidence, the Court left the reasonableness of this specific warrant, and the good-faith question, for the Fourth Circuit. That is a familiar pattern in Fourth Amendment cases: the Court settles the threshold question of what counts as a search and lets the lower courts sort out remedies on the particular facts. For readers tracking the broader trend, Chatrie connects to the site's coverage of the FISA Section 702 surveillance lapse and to state-level fights over automated license-plate readers described in the Norfolk Flock camera appeal. What the ruling does not do is predict how any individual suppression motion will come out; it sets the constitutional baseline and leaves application to the facts.

How This Affects You

This section describes general implications, not advice about any specific situation. After Chatrie, a geofence or reverse-location request for phone data is a Fourth Amendment search nationwide, which generally means investigators must satisfy the warrant standards courts apply to searches. People who use location-aware apps generate exactly the kind of Location History records these warrants target, and the ruling recognizes a privacy interest in those records even though a company stores them. The decision does not make every past geofence search invalid, and it does not by itself decide whether evidence in any pending case will be suppressed; those questions turn on reasonableness and good faith, which courts will assess case by case. Anyone facing a specific legal question about location data in an investigation should consult a lawyer licensed in the relevant jurisdiction.

What Happens Next

The case now returns to the Fourth Circuit. On remand, that court will consider whether the geofence search was reasonable and whether the good-faith exception allows the government to use the Location History evidence despite the constitutional ruling. Because the Supreme Court decided only that a search occurred, the outcome of Chatrie's own suppression fight is not yet settled.

Beyond this case, lower courts and investigators across the country now have a controlling rule: obtaining geofence location data is a search. Expect law enforcement agencies and technology providers to adjust how they draft and respond to reverse-location requests, and expect further litigation over what makes such a warrant sufficiently particular. The event that would turn any of those questions into settled national law is a future Supreme Court decision addressing the reasonableness standard for geofence searches, which Chatrie expressly did not resolve.

This is general legal information, not legal advice. It covers a federal Fourth Amendment decision that applies nationwide and reflects sources verified on July 1, 2026. Laws change and this matter is developing on remand; consult a lawyer licensed in your jurisdiction about your specific situation.

Sources

Last updated: 2026-07-01. This is a developing story; details verified as of 2026-07-01.

Frequently Asked Questions

Did the Supreme Court decide Chatrie v. United States?

Yes. On June 29, 2026, the Court decided Chatrie v. United States (No. 25-112) by a 6-3 vote, holding that using a geofence warrant to obtain a person's Google location data is a Fourth Amendment search. The Court then vacated the Fourth Circuit judgment and remanded.

What did the Court actually hold?

The Court held that a person has a reasonable expectation of privacy in records of a phone's location, so the government conducts a Fourth Amendment search when it demands that data through a geofence warrant, even from a third party like Google and even for a limited time window.

Did the Supreme Court rule geofence warrants unconstitutional?

No. The Court held only that a geofence request is a search. It did not decide whether this warrant was reasonable or whether the evidence must be suppressed. It vacated and remanded so the Fourth Circuit can address reasonableness and the good-faith exception.

How does Chatrie relate to Carpenter v. United States?

Carpenter, 585 U.S. 296 (2018), held that accessing historical cell-site location data is a search even though a carrier holds it. Chatrie extends that logic, declining to apply the third-party doctrine to Google Location History obtained through a geofence warrant.

Who was in the majority and who dissented?

Justice Kagan wrote the majority, joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, and Jackson. Justice Gorsuch concurred in the judgment on a property theory, giving six votes for the result. Justices Alito, Thomas, and Barrett dissented in part.

What is a geofence warrant?

A geofence warrant, or reverse-location warrant, orders a provider such as Google to identify devices that were inside a defined map area during a defined time window. It begins with a location and works toward identifying users, rather than naming a suspect first.

What happens to Okello Chatrie's case now?

The case returns to the Fourth Circuit. That court will decide whether the geofence search was reasonable and whether the good-faith exception lets the government use the evidence. The Supreme Court did not resolve those questions.

Updates

Independently fact-checked against the cited primary sources

Sources and References

  1. Chatrie v. United States, No. 25-112, 609 U.S. ___ (2026) (slip opinion, decided June 29, 2026)(supremecourt.gov).gov
  2. Chatrie v. United States (No. 25-112), Cornell Legal Information Institute(law.cornell.edu)
  3. Carpenter v. United States, 585 U.S. 296 (2018) (slip opinion, No. 16-402)(supremecourt.gov).gov
  4. Geofence Warrants and the Fourth Amendment, Congressional Research Service Legal Sidebar LSB11274(congress.gov).gov
  5. Docket, Chatrie v. United States, No. 25-112(supremecourt.gov).gov
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