Supreme Court Rules on Geofence Warrants in Chatrie

After a whirlwind of decisions, the Supreme Court wrapped up its term on Monday, releasing its final batch of decisions. One of these is Chatrie v. United States, a somewhat surprising decision that protected Americans’ tech privacy under the Fourth Amendment. SCOTUS concluded that obtaining location data from tech companies through a geofence warrant now counts as a Fourth Amendment search, requiring a valid warrant to do so. 

That’s a reversal from where things looked to be heading. During oral arguments this past April, the Court sounded like they were ready to let geofence warrants persist with limited time and space. 

The 6-3 decision tackled the application of geofence warrants, which allow law enforcement to pull cell-phone data from all individuals within a certain perimeter and time period. The case surrounds Okello Chatrie’s arrest following a robbery in which the geofence warrants, served on Google, identified his involvement. 

Justice Kagan delivered the Opinion of the Court, clarifying that the Court took the case only to determine whether the police violated the Fourth Amendment in obtaining Chatrie’s data, leaving it to the Fourth Circuit to decide whether the warrant’s multi-step process met the Amendment’s particularity and probable cause requirements. 

The Opinion of the Court first examined whether a Fourth Amendment search occurred at all, applying Katz v. United States’s reasonable-expectation-of-privacy test, despite some dissenting members’ push to discard that precedent entirely. Their acknowledgment that surveillance technology makes it easier for the government to peer into personal lives is an optimistic sign that cases in the future will protect citizens from excessive intrusion. 

The bulk of the Opinion of the Court leaned on the 2018 case Carpenter v. United States, which established that police need a warrant to gather Cell Site Location Information (CSLI) because that kind of data offers near-perfect surveillance of someone’s life. Chatrie’s Location History appeared to be an even sharper version of the same issue: CSLI could place an individual within an area as large as four square miles, whereas Location History pinned Chatrie to twenty meters, logging his position about seven times as often as CSLI could. If the less precise technology required a warrant, the Court reasoned, so does the more accurate one. The Court also rejected the government’s reliance on the third-party doctrine–the general rule that you lose Fourth Amendment protection over information voluntarily given up to a third-party–since Carpenter had previously declined to apply that doctrine to this type of data, and the Court saw no reason to treat Location History differently. 

As expected, the third-party doctrine was a hot topic going into this case, and it’ll only be more relevant as more details of individuals’ daily lives get logged by apps they don’t think twice about using. With Chatrie decided, we can expect courts to lean away from applying the doctrine as it applies to location data specifically, treating it as too involuntary, too revealing, to count as something people actually choose to hand over. 

Using Katz and Carpenter, the Court set a precedent in tech privacy, solidifying the idea that the Fourth Amendment extends to the complexities of the digital age. 

Justice Jackson, in a concurrence joined by Justice Sotomayor, elaborated on the Opinion of the Court–though both had signed onto Kagan’s majority opinion in full, this was more a matter of emphasis. Jackson honed in on the geofence warrant’s multi-step process, where officers narrowed down device owners to a specific suspect list without criteria set by an independent magistrate, as the Fourth Amendment requires. Gorsuch, meanwhile, took an entirely different approach: he opposed the use of Katz altogether, arguing for a more concrete and literal interpretation of the Fourth Amendment. Although he reached his conclusion differently, he still arrived at the same place as the majority: accessing Chatrie’s location history without a warrant violates the Fourth Amendment. 

Justice Alito delivered a striking dissenting opinion, joined in part by Justices Thomas and Barrett–Barrett also gave a separate dissent of her own. Alito attacked the Court’s decision to grant the case certiorari, writing that “this outcome was guaranteed as soon as this Court granted certiorari”. He reasoned that the Fourth Circuit had already found the police acted in good faith, and the Court declined to revisit that finding when it took the case, meaning that Chatrie’s conviction stands regardless of what the Court decides about the Fourth Amendment. As for the third-party doctrine, he argued that Chatrie voluntarily gave up the information to Google, so law enforcement didn’t need a warrant in the first place. 

Ultimately, the dissenting opinion exposes the obstacles that must be overcome to preserve citizens’ privacy, and this case has at least two built right in. 

The first is procedural. The Court didn’t strike down the warrant outright; it remanded the case to the Fourth Circuit to decide whether the warrant was specific enough and whether the good-faith exception still allows prosecutors to keep the evidence. But that’s not really a question about Chatrie’s fate–that part of the case is already settled. What’s really at stake on remand is whether courts will start holding geofence warrants to the Fourth Amendment’s particularity and probable-cause requirements, or whether police keep the unchecked authority that Jackson outlined in her concurrence–a discretion that, in this case, pulled location data of 16 people who were never cited as suspects, including trips to their homes, schools, and a hospital, before narrowing down the list to three. That’s the modern version of a general warrant: search first, sort out relevance later. Whether the Fourth Circuit resolves that discrepancy is a part of this case that proves extremely relevant for ordinary, law-abiding Americans who get swept into a geofence. 

The second is practical, and it’s buried in the Court’s footnotes: Google changed how it stores Location History in July 2025, specifically so that it can no longer respond to this type of warrant. The technology at the center of this case is already irrelevant. Even the ACLU lawyer who helped argue Chatrie’s side acknowledged as such while celebrating the ruling, noting that other companies running similar data-gathering aren’t affected by this decision at all. 

This was, undoubtedly, a big win for tech privacy. By using Carpenter as a precedent for location-data warrants and refusing to apply the third-party doctrine to this kind of information, the Court protected Americans from unlawful intrusion. But it’s not a guaranteed continuous win: Google has stopped collecting this specific data the way it used to, but other apps haven’t, and nothing in this ruling stops the next one from filling the gap that Google just left.