Chatrie v. United States

Docket Number: 25-112
Citation: 609/2
Term: October Term 2025
Argued: April 27, 2026
Decided: June 29, 2026
Lower Court: United States Court of Appeals for the Fourth Circuit
Author: Associate Justice Elena Kagan
Concurring: Elena Kagan, John G. Roberts, Jr., Sonia Sotomayor, Brett M. Kavanaugh, Ketanji Brown Jackson, Neil M. Gorsuch
Dissenting: Samuel A. Alito, Jr., Clarence Thomas, Amy Coney Barrett

AI-Generated Summary

Case Information:

Facts of the Case:

On May 20, 2019, an armed robber stole $195,000 from a credit union in Midlothian, Virginia. Police obtained witness statements and surveillance footage showing the robber approaching the bank while appearing to use a cell phone, but they identified no suspect.
On June 14, 2019, officers obtained a geofence warrant from a Virginia magistrate directed to Google. The warrant authorized a three-step process to obtain Location History data: (1) anonymized location points for all devices within a 150-meter radius of the credit union for a one-hour window; (2) additional anonymized data for a narrowed subset over a two-hour window both inside and outside the geofence; and (3) identifying information (names, email addresses, phone numbers) for a further narrowed subset.
Google produced data identifying three users, including petitioner Okello Chatrie, whose records placed him inside the geofence shortly before the robbery. Further investigation led to Chatrie’s indictment on robbery and firearms charges.
Chatrie moved to suppress the Location History evidence, contending that the geofence warrant violated the Fourth Amendment. The District Court found the warrant defective but admitted the evidence under the good-faith exception. A Fourth Circuit panel affirmed on the ground that no search occurred. After rehearing en banc, the Fourth Circuit affirmed in a one-sentence per curiam opinion, dividing evenly on whether a search had taken place.

Legal Issues Presented:

Whether police officers conducted a Fourth Amendment search by obtaining Chatrie’s Location History data from Google through a geofence warrant.
The case requires interpretation of the Fourth Amendment’s protection against unreasonable searches, specifically whether an individual has a reasonable expectation of privacy in cell-phone location records held by a third party.
The parties disputed whether the third-party doctrine applied, whether the limited duration of the data obtained negated any privacy interest, and whether the multi-step warrant satisfied probable-cause and particularity requirements.

The Court's Decision (Main Opinion):

Author & Type: Justice Kagan delivered the opinion of the Court (joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, and Jackson).
Holding: Obtaining Chatrie’s Location History data constituted a Fourth Amendment search because an individual has a reasonable expectation of privacy in his cell-phone location information.
Legal Reasoning: The Court reasoned that Location History data provides an even more precise record of movements than the cell-site location information at issue in Carpenter v. United States, 585 U. S. 296 (2018). It rejected the Government’s arguments that the short duration of the data or the third-party doctrine removed Fourth Amendment protection, emphasizing that cell-phone location records are not truly “shared” in the ordinary sense and that modern cell-phone use is indispensable to daily life. The Court declined to decide whether the particular multi-step warrant was valid.
Disposition: The judgment of the Fourth Circuit was vacated and the case remanded for further proceedings.

Concurring Opinion(s):

Justice Jackson filed a concurring opinion (joined by Justice Sotomayor), agreeing that a search occurred and stating that she would have held the search unreasonable because the warrant failed to supply particularized probable cause at the second and third stages of the process.
Justice Gorsuch filed an opinion concurring in the judgment, agreeing that a search occurred but urging a property-based analysis of the Fourth Amendment rather than the reasonable-expectation-of-privacy test.

Dissenting Opinion(s):

Justice Alito filed a dissenting opinion (joined by Justice Thomas as to Part I and by Justice Barrett as to Parts II–B, II–C–1, and II–C–2), arguing that the Court’s opinion was advisory because the good-faith exception independently supported the judgment below and that neither traditional Fourth Amendment doctrine nor Carpenter required a warrant for the geofence procedure.
Justice Barrett filed a dissenting opinion, agreeing with Justice Alito that Chatrie had no reasonable expectation of privacy in the voluntarily disclosed location data.

Potential Significance:

The decision establishes that government acquisition of Location History data from a third-party service provider constitutes a Fourth Amendment search, extending the reasoning of Carpenter to this form of cell-phone location information. The Court leaves unresolved whether the specific multi-step geofence warrant satisfied the Fourth Amendment’s probable-cause and particularity requirements, remanding that question to the Court of Appeals.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: Cell Phone Location Data, Geofence Warrants, Location Privacy