Chatrie v. United States
No. 25-112 · Decided June 29, 2026 · vacated and remanded
Did law enforcement officials conduct a search under the Fourth Amendment when they acquired petitioner's cell-phone location data from Google via a geofence warrant? Police officers conduct a Fourth Amendment search when they acquire a user's cell-phone "Location History" data from a third-party provider because individuals maintain a reasonable expectation of privacy in that information.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR · Argued April 27, 2026
Parties — Petitioner: CHATRIE · Respondent: UNITED STATES
Vote & lineup6–3 on the judgment. Kagan delivered the opinion of the Court, joined by Roberts, Sotomayor, Kavanaugh, Jackson (5). Dissent(s): Alito (joined by Thomas, Barrett); Barrett. Concurrence(s): Jackson (joined by Sotomayor); Gorsuch.
Who prevailed — The petitioner prevailed on the question of whether a Fourth Amendment search occurred, though the case was remanded to determine if the search was reasonable.
The question

Did law enforcement officials conduct a search under the Fourth Amendment when they acquired petitioner's cell-phone location data from Google via a geofence warrant? If so, did the multi-step process authorized by the warrant make that search reasonable? Specifically, the Court addresses whether an individual maintains a reasonable expectation of privacy in "Location History" data stored by a third-party technology company.

Petitioner's argument
  • The acquisition of Location History data constitutes a Fourth Amendment search.
  • The geofence warrant was invalid because it functioned as an "unconstitutional general warrant."
  • The search was insufficiently described and lacked probable cause.
  • The warrant granted too much discretion to police officers and too little oversight to the magistrate.
Respondent's argument
  • No Fourth Amendment search occurred because the petitioner had no reasonable expectation of privacy in data voluntarily exposed to Google.
  • The third-party doctrine precludes Fourth Amendment protections for information shared with a tech company.
  • Accessing a short window of location data (two hours) does not constitute a search as it reveals little about personal life.
  • The warrant was valid as it sought particularized information based on probable cause to solve a crime.
The decision
  • The Court held that police conducted a Fourth Amendment search when they acquired Location History data because individuals have a reasonable expectation of privacy in their cell-phone location information.
  • Relying on *Carpenter v. United States*, the Court reasoned that Location History is "qualitatively different" from other third-party records because it provides a "detailed" and "encyclopedic" portrait of a person's movements.
  • The Court noted that Location History is more intrusive than cell-site location information (CSLI), offering greater precision (within 20 meters), more frequent charting (averaging 720 times daily), and elevation data.
  • The Court rejected the argument that short-term monitoring is not a search, citing *United States v. Jones* to note that even brief tracking can reveal "a wealth of detail" about private associations.
  • Invoking *Kyllo v. United States*, the Court stated that Fourth Amendment protections apply regardless of the "quality or quantity of information" obtained.
  • The Court declined to apply the third-party doctrine established in *United States v. Miller* and *Smith v. Maryland*, finding that Location History is not "truly shared" since smartphones are "indispensable to participation in modern society" (*Carpenter*).
  • The Court found that enabling Location History is not a truly voluntary choice because Google prompts users and warns that devices may not "work correctly" without the service.
  • The Court vacated the lower court's judgment and remanded the case to determine if the specific multi-step warrant satisfied the Fourth Amendment's requirements of particularity and probable cause.
Separate opinions
Jackson, concurring (joined by Sotomayor)
  • Argues the search was unconstitutional because the second and third steps of the warrant lacked explicit criteria for narrowing the list of suspects.
  • Contends the warrant gave officers a "roving commission" without a "judicial check" from a neutral magistrate, citing *Berger v. New York* and *Steagald v. United States*.
Gorsuch, concurring
  • Rejects the *Katz v. United States* "reasonable expectation of privacy" test as lacking a basis in the Constitution's text or history.
  • Argues that Location History data constitutes a "personal effect" (property) under the original meaning of the Fourth Amendment.
  • Cites state laws in Virginia, Texas, and Georgia that treat computer data as property to support the claim that the data is a personal effect.
Alito, dissenting (joined by Thomas, Barrett)
  • Argues the opinion is "advisory" because the "good-faith exception" from *United States v. Leon* would likely prevent the suppression of evidence.
  • Contends the third-party doctrine should apply under *United States v. Miller* and *Smith v. Maryland* because the data was voluntarily conveyed to Google.
  • Argues *Carpenter v. United States* should not apply because the data spanned only two hours, not the "extended period" required for a search.
Barrett, dissenting
  • Argues that the petitioner had no reasonable expectation of privacy in data regarding public movements voluntarily disclosed to a third party.
Read the full opinion on supremecourt.gov (PDF) →