NACDL - Chatrie v. United States

Chatrie v. United States

The United States Supreme Court has issued its opinion in Chatrie v. United States, a landmark case challenging the constitutionality of geofence warrants that allow police to sweep up Google “Location History” data from anyone near a crime scene in search of a suspect. Chatrie is the first constitutional challenge to a geofence warrant in the country. Geofence warrants require Google to search hundreds of millions of users to identify devices near the scene of the crime. NACDL's Fourth Amendment Center has been litigatting this issue and this case since the beginning.

The Supreme Court held that individuals retain a reasonable expectation of privacy in their digital location data, even for short periods, and even though a third party holds that data in the cloud. While the Court established that a Fourth Amendment search occurred, it did not determine whether this specific geofence warrant violated the Fourth Amendment’s probable cause and particularity requirements, remanding the case back to the Fourth Circuit for further proceedings.

A Virginia district court initially found the warrant unconstitutional but found that law enforcement had relied on the warrant in good faith and declined to suppress the evidence. United States v. Chatrie, 590 F. Supp. 3d 901 (E.D. Va. 2022). The Fourth Circuit, sitting en banc, affirmed the district court's decision in a single-sentence per curium opinion, followed by nine concurrences and dissents, totalling 126 pages. United States v. Chatrie, 2025 WL 1242063 (4th Cir. Apr. 30, 2025).

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