The Supreme Court of the United States has ruled that police officers conducted a Fourth Amendment search when they obtained cell phone location data from Google in the case of Chatrie v. United States (Docket No. 25-112). This decision, issued on June 29, 2026, affirms that individuals have a reasonable expectation of privacy in their cell phone location information. This ruling is significant as it addresses the growing use of geofence warrants by law enforcement to track individuals' movements through their cell phone data.
The case arose from a bank robbery in Midlothian, Virginia, on May 20, 2019. The robber approached the credit union while appearing to talk on a cell phone, but local police could not identify him initially. After conducting an investigation, the police applied for a geofence warrant, which allowed them to request location data from Google for all cell phones within a 150-meter radius of the crime scene during a specified time frame. The warrant led to the identification of Okello Chatrie as a suspect based on his location data.
Chatrie was charged with robbery and related firearms offenses, but he moved to suppress the evidence obtained from Google, arguing that the warrant was invalid under the Fourth Amendment. The District Court agreed that the warrant violated Chatrie's rights but denied the motion based on the good-faith exception, allowing the evidence to be used in court. The Fourth Circuit Court of Appeals affirmed this decision, stating that no search occurred because Chatrie had no reasonable expectation of privacy in the data voluntarily shared with Google.
The Supreme Court's ruling focused on whether the police's acquisition of Chatrie's location data constituted a Fourth Amendment search. Justice Elena Kagan, writing for the majority, stated, "An individual has a reasonable expectation of privacy in records about his cell phone's location, and police intrude on that constitutionally protected interest when they demand the information." The court concluded that accessing such data does indeed qualify as a search under the Fourth Amendment.
The court emphasized that the Fourth Amendment is designed to protect individuals from arbitrary government invasions of privacy. The ruling aligns with previous decisions, particularly the 2018 Carpenter v. United States case, which established that accessing cell-site location information (CSLI) constitutes a Fourth Amendment search. The court noted that the same reasoning applies to Location History data, which provides an even more detailed account of a person's movements than CSLI.
In their opinion, the justices highlighted that the nature of modern smartphones makes them indispensable to daily life, and the data they generate can reveal intimate details about an individual's life. Justice Kagan noted that "Location History provides an even more fine-tuned picture of a person's movements," allowing police to conduct extensive surveillance of individuals without their knowledge.
The court's ruling has significant implications for law enforcement practices. It reinforces the necessity for police to obtain a warrant based on probable cause before accessing individuals' location data from technology companies. This decision also raises questions about the legality of geofence warrants, which have been increasingly used by law enforcement to identify suspects in criminal investigations.
Moving forward, this ruling may lead to greater scrutiny of geofence warrants and similar practices. It emphasizes the importance of protecting individuals' privacy rights in the digital age, where technology plays a crucial role in everyday life. The decision may also prompt lawmakers to revisit privacy laws and regulations surrounding the collection and use of personal data by law enforcement.
As for what comes next, the case has been sent back to the Fourth Circuit Court of Appeals to determine whether the warrant issued for Chatrie's data met the Fourth Amendment's requirements of particularity and probable cause at each step of the search process. This means that while the Supreme Court has clarified the expectation of privacy in cell phone location data, further legal questions remain regarding the specific warrant used in this case.