Chatrie v. United States
No. 25-112 · Decided June 29, 2026 · vacated and remanded
Did the police conduct a Fourth Amendment search 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 an individual's cell-phone Location History data from a third-party provider because individuals have a reasonable expectation of privacy in that information.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT · 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 the acquisition of his location data constituted a Fourth Amendment search, resulting in the vacation and remand of the lower court's judgment.
The question

Did the police conduct a Fourth Amendment search when they acquired petitioner's cell-phone location data from Google via a geofence warrant? If so, did the multi-step process authorized by that warrant satisfy the requirements of reasonableness, particularity, and probable cause? Specifically, does an individual maintain a reasonable expectation of privacy in "Location History" data stored by a third-party provider?

Petitioner's argument
  • The acquisition of Location History data constitutes a Fourth Amendment search because it reveals intimate details of a person's life.
  • The geofence warrant used by the police was invalid as it functioned as an unconstitutional general warrant.
  • The search process lacked sufficient particularity and probable cause at each stage of its execution.
Respondent's argument
  • No Fourth Amendment search occurred because petitioner had no reasonable expectation of privacy in location data voluntarily exposed to Google.
  • The "third-party doctrine" precludes the Fourth Amendment from applying to records held by a tech company.
  • Accessing only a short window of time (two hours) does not constitute a search as it reveals little about the details of a person's personal life.
The decision
  • The Court held that police conducted a Fourth Amendment search when they acquired petitioner's Location History data from Google.
  • Relying on *Carpenter v. United States*, the Court reasoned that individuals have a reasonable expectation of privacy in the "whole of their physical movements."
  • The Court found that Location History is even more intrusive than cell-site location information (CSLI) because it is more precise (within 20 meters), more frequent (averaging 720 chartings daily), and can reveal elevation.
  • The Court rejected the argument that short-term monitoring avoids Fourth Amendment scrutiny, citing *United States v. Jones* to note 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 declined to apply the third-party doctrine, noting in *Carpenter* that CSLI is "qualitatively different" from bank records (*United States v. Miller*) and dialed phone numbers (*Smith v. Maryland*).
  • It reasoned that Location History is not "truly shared" because smartphones are "indispensable to participation in modern society" and users are often prompted to enable the service for their devices to "work correctly."
  • 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 violated the Fourth Amendment because steps two and three of the warrant lacked specific criteria and magisterial oversight.
  • Claims this gave officers a "roving commission" to collect data without judicial checks, 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 constitutional text or history.
  • Argues that Location History data constitutes an "effect" (personal property) under the Fourth Amendment's text, citing *Byrd v. United States* and various state computer crime laws.
Alito, dissenting (joined by Thomas, Barrett)
  • Argues the opinion is "advisory" because the "good-faith exception" from *United States v. Leon* would likely bar suppression of the evidence regardless of the search's legality.
  • Contends that under *United States v. Miller*, *Smith v. Maryland*, and *United States v. Knotts*, no search occurred because the data was voluntarily shared and limited to a brief two-hour window.
Barrett, dissenting
  • Agrees with Justice Alito that petitioner had no reasonable expectation of privacy in data about public movements voluntarily disclosed to Google.
Read the full opinion on supremecourt.gov (PDF) →