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 "Location History" data from Google via a geofence warrant? The Court held that police conducted a Fourth Amendment search when they acquired petitioner's Location History data because an individual has a reasonable expectation of privacy in such information.
Vote & lineupKagan delivered the opinion of the Court, joined by Roberts, Sotomayor, Kavanaugh, Jackson (5). Dissent(s): Alito (joined by Thomas); Barrett. Concurrence(s): Jackson (joined by Sotomayor); Gorsuch.
The question
Did law enforcement officials conduct a search under the Fourth Amendment when they acquired petitioner's "Location History" data from Google via a geofence warrant? If so, did the multi-step warrant used to obtain this data make the search reasonable? The Court granted certiorari solely to determine whether the police violated the Fourth Amendment in obtaining this location data.
Petitioner's argument
Petitioner sought to suppress the location data obtained by the police. He argued that the acquisition of this data constituted a Fourth Amendment search. He further contended that the geofence warrant authorizing the search was invalid.
Respondent's argument
Respondent sought to admit the evidence and maintain the convictions. The Government argued that no search occurred because petitioner had no reasonable expectation of privacy in a short window of location data. Respondent further contended that the third-party doctrine applies because petitioner voluntarily authorized Google to collect and retain the information.
The decision
The Court held that police conducted a Fourth Amendment search when they acquired petitioner's Location History data because an individual has a reasonable expectation of privacy in such information. Relying on *Carpenter v. United States*, the Court reasoned that Location History provides an even more "detailed" and "encyclopedic" portrait of movements than cell-site location information (CSLI). The Court noted that Location History is more precise than CSLI, recording location every two minutes and estimating elevation to reveal specific floors of a building. It further observed that Location History resembles private materials like emails or calendars that users reasonably expect to be shielded from "inquisitive eyes." The Court rejected the argument that short-term monitoring is not a search, citing *United States v. Jones* to show that even brief tracking reveals a "wealth of detail" about personal 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 also declined to apply the third-party doctrine, following *Carpenter*'s finding that location data is "qualitatively different" from the bank records in *United States v. Miller* or dialed numbers in *Smith v. Maryland*. It reasoned that such data is not truly "shared" because cell phones are "indispensable to participation in modern society." The Court found that opting into Location History is not a truly voluntary choice because Google prompts users and warns that devices may not "work correctly" otherwise. Consequently, the Court vacated the lower court's judgment and remanded the case to determine if the specific warrant satisfied the Fourth Amendment's requirements of particularity and probable cause.
Dissent summary
Justice Alito, joined by Justice Thomas (Part I) and Justice Barrett (Parts II-B, II-C-1, and II-C-2), argued that the police did not need a warrant. He contended that the third-party doctrine applies under *United States v. Miller* because petitioner voluntarily conveyed his location information to Google. Alito further relied on *United States v. Knotts* to argue that the brief two-hour duration of the tracking did not constitute the "all-encompassing record" required to trigger *Carpenter*'s warrant requirement.