Chatrie v. United States

Questions presented

SCOTUS records, cert granted 16 Jan 2026

1. This case concerns the constitutionality of geofence warrants. For cell phone users to use certain services, their cell phones must continuously transmit their exact locations to their service providers. A geofence warrant allows law enforcement to obtain, from the service provider, the identities of users who were in the vicinity of a particular location at a particular time. In this case, law enforcement obtained, and served on Google, a geofence warrant seeking anonymized location data for every device within 150 meters of the location of a bank robbery within one hour of the robbery. After Google returned an initial list, law enforcement sought - without seeking an additional warrant - information about the movements of certain devices for a longer, two-hour period, and Google complied with that request as well. Then - again without seeking an additional warrant-law enforcement requested de-anonymized subscriber information for three devices. One of those devices belonged to petitioner Okello Chatrie. Based on the evidence derived from the geofence warrant, petitioner was convicted of armed robbery. The questions presented are:
2. Whether the execution of the geofence warrant violated the Fourth Amendment.
3. Whether the exclusionary rule should apply to the evidence derived from the geofence warrant.

Opinion summary

Etalia.ai summary of the majority opinion

Justice Kagan wrote that police conducted a Fourth Amendment search when they obtained Okello Chatrie’s cell-phone location data from Google through a geofence warrant. The Court reasoned that people have a reasonable expectation of privacy in cell-phone location information, and that Google’s Location History is even more detailed and revealing than the location records at issue in Carpenter. The Court rejected the Government’s arguments that the short duration of the data, its storage with a third party, or the user’s choice to turn on the feature made the search outside the Fourth Amendment. The Court did not decide whether the warrant was ultimately valid. Because the lower court had not addressed whether each step of the warrant satisfied particularity and probable cause, the Court vacated and remanded for the court of appeals to consider that question.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Alito dissented, joined by Justice Thomas as to Part I and by Justice Barrett as to Parts II-B, II-C-1, and II-C-2. He said the Court was expanding Carpenter beyond its limits and turning the Fourth Amendment into protection for sensitive personal information held by third parties. He argued that traditional Fourth Amendment principles, focused on searches of a person’s own papers and effects and on property rights, did not support Chatrie’s claim. He also said the case was an odd vehicle because the geofence procedure was now obsolete, and he criticized the majority for announcing broad rules in a case that should have been resolved more narrowly. Justice Barrett also filed a separate dissent, but the text provided does not include her reasoning.