United States v. Chatrie

In 2019, law enforcement issued a geofence warrant in response to an armed robbery at a credit union in Virginia. Geofence warrants direct Google or other tech companies to hand over location data from every user’s cell phone or other device the company estimates was in a certain area during a certain time frame. These warrants are increasingly common, but they raise serious questions under the Fourth Amendment because they are dragnets, typically issued without police demonstrating reason to believe any or all the people who own those devices were involved in any crime.

The geofence warrant at use in this case compelled Google through a multi-step process to disclose location history of users who were estimated to be within a 150-meter radius of the incident—an area as big as several football fields that encompassed residential buildings, businesses, and a church. The warrant also allowed police to obtain additional location information about individuals that were ensnared in the initial dragnet.

Following Mr. Chatrie’s conviction for the armed robbery, based in large part on evidence obtained from the geofence warrant, he appealed his conviction to the U.S. Court of Appeals for the Fourth Circuit. The Fourth Circuit issued a divided opinion but ultimately allowed prosecutors to use the evidence it had gathered through the geofence search.

In January 2026, the Supreme Court agreed to hear the case. The ACLU, ACLU of Virginia, Electronic Frontier Foundation, and the Center on Privacy & Technology at Georgetown Law filed an amicus brief asserting that geofence warrants are never a permissible investigatory method under the Fourth Amendment. Geofence searches are unconstitutional general warrants that fail the Fourth Amendment’s probable cause, particularity, and judicial review requirements, and they be should categorically rejected by courts.