Chatrie v. United States: The Warrant Rule for Location Data Just Got Simpler… and Harder
WRITTEN BY: Brian Tully
On June 29, 2026, the Supreme Court decided Chatrie v. United States. If you work cases that touch location data, this one impacts your work. The takeaway: when police obtain a person’s location data from a company like Google, that is a Fourth Amendment search, and you need a warrant. It does not matter the length of your request. If it is location data held by a third party, get a warrant.
The Robbery
In 2019, a man robbed a credit union outside Richmond, Virginia. Witnesses and camera footage showed him approaching from a nearby church while appearing to talk on a cell phone. The man walked in and demanded $100,000 from the teller. When the teller said she did not have access to that much cash, the man forced the manager at gun point to open the vault and left with $195,000.
Investigators applied for a geofence warrant to Google, drawing a 150-meter circle around the scene and asking for the phones inside it around the time of the robbery.
The warrant used the three step Google process. Step one produced anonymized data for 19 phones inside the geofence. Step two narrowed the list to nine and pulled two hours of movement, inside and outside the circle. Step three narrowed to three and returned names. One of them was Okello Chatrie, whose data placed him at the scene about ten minutes before the robbery. Chatrie moved to suppress the evidence.
The lower courts split badly. The trial judge said the warrant violated the Fourth Amendment but admitted the evidence under the good faith exception. A Fourth Circuit panel said there was no search at all. The full Fourth Circuit deadlocked seven to seven on that question. The Supreme Court took one issue: was this a search?

What the Court Decided
Writing for the majority, Justice Kagan held that a person has a reasonable expectation of privacy in cell phone location data, and that accessing Location History is a search. The Court leaned on Carpenter v. United States, the 2018 CSLI case, and found that everything that made CSLI a search applies just as strongly, or more strongly, to Location History. Having found a search, the Court sent the case back to the Fourth Circuit to decide whether this multi-step warrant actually satisfied probable cause and particularity at each step.
The specific geofence Google technique is largely gone already. In July 2025, Google moved Location History onto individual devices and now says it cannot respond to these warrants at all. So, the exact technique in Chatrie is off the table, but do not dismiss the importance of the decision. The Court wrote broadly, and its reasoning reaches any location data held by any provider.
What This Means for Your Cases
- Get a Search Warrant every time. Do not rely on the old arguments. Forget the 2703(d) orders. Do not lean on a short time window. If you are seeking location data from a company, assume you need a warrant supported by probable cause. For years, many state courts have required Search Warrants for any location data. Now that rule is nationwide.
- The reasoning travels. The Google technique is dead, but the logic covers Apple, Uber, Lyft, Snapchat, and whatever comes next. Do not treat a different provider as a warrant free workaround.
- Remember Particularity. The dissent noted that when a request sweeps in private location data you did not need, the remedy is suppressing that piece, not the whole case. Narrow requests protect the rest of your evidence. Be able to explain why you chose the geographical size of the request (in Chatrie, the 150-meter radius) and the time frame. Avoid Constitutionally sensitive areas. In the written and oral arguments, much was discussed that the radius of the Chatrie geofence warrant contained a church. If your location request includes places of worship, abortion clinics, political organizations, or medical facilities, be able to explain why these locations are in the Search Warrant request.
- Watch the horizon. The dissent warned that search history, purchase logs, and payment records could be next. The doctrine has not moved there yet, but if you are building around sensitive third party digital records, the safe course is a warrant.
Bottom Line
Chatrie makes the rule cleaner. When you want location data from a provider, get a warrant. The hard part moves to the paper. Write the affidavit and the warrant so that every step stands on its own probable cause and its own particularity.
Brian Tully recently retired from the Massachusetts State Police and is considered an SME regarding digital forensic evidence.





