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📝 Page Status: Draft — sourced but not yet reviewed

  • Status: draft
  • Sources: 4
  • Relationships: 4
  • Research debt items: 6

Chatrie v. United States

Summary

Chatrie v. United States, No. 25-112 (U.S. June 29, 2026), held that police officers conducted a Fourth Amendment search when they acquired Okello Chatrie’s Google Location History data because an individual has a reasonable expectation of privacy in cell-phone location information. The Court vacated the Fourth Circuit and remanded questions about whether the multi-step geofence warrant satisfied particularity and probable cause.

Verified Facts

  • The Supreme Court decided the case on June 29, 2026, No. 25-112, on certiorari to the Fourth Circuit.1
  • The case arose from a May 20, 2019 credit-union robbery in Midlothian, Virginia; police later obtained a geofence warrant directed to Google for phones within about 150 meters of the crime scene near the time of the robbery.1
  • The warrant described a three-step process culminating in identifying information for narrowed Location History users; Google ultimately produced identifying information including petitioner Okello Chatrie.1
  • Held: police conducted a Fourth Amendment search when they acquired Chatrie’s location data from Google because an individual has a reasonable expectation of privacy in his cell-phone location information.1
  • The Court relied on and extended the privacy framework of Carpenter v. United States, including that people have a reasonable expectation of privacy in the whole of their physical movements.12
  • The Court rejected applying the third-party doctrine to Location History in the circumstances presented, explaining that a cell-phone user is not to be viewed as sharing private information with third parties (freely passable to the government) just by doing ordinary cell-phone things.1
  • The Court did not decide whether the particular multi-step warrant was reasonable; it vacated and remanded for the Fourth Circuit to assess particularity and probable cause at each step.1
  • Justice Kagan delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, and Jackson; Justices Jackson and Gorsuch filed concurrences; Justices Alito and Barrett filed dissents.1

Historical Context

Geofence (reverse-location) warrants ask providers for devices present in a place and time window, often before police know a suspect’s identity. Chatrie is a major post-Carpenter digital-privacy decision on Google Location History obtained through that process. Secondary commentary has framed the ruling together with state efforts to restrict reverse keyword warrants.3

Authority level: U.S. Supreme Court holding that acquiring Location History via the geofence process is a Fourth Amendment search; warrant validity left open on remand. Do not treat Chatrie as settling particularity/probable-cause rules for all geofence warrants. Prefer the slip opinion / LII text over secondary summaries for holdings.

Commentary (secondary)

ACLU senior policy counsel Chad Marlow’s July 30, 2026 Hill opinion describes reverse location and reverse keyword warrants as technology-driven general warrants, praises Chatrie’s search holding and remand, and urges state/federal legislation including Delaware reverse-keyword limits and the Fourth Amendment Is Not For Sale Act.3 Treat as advocacy commentary, not holdings.

Relationships

  • CASE-CHATRIE-V-US cites SRC-CHATRIE-LII.
  • CASE-CHATRIE-V-US cites SRC-CHATRIE-SCOTUS-PDF.
  • CASE-CHATRIE-V-US related_to TOPIC-FOURTH-AMENDMENT.
  • CASE-CHATRIE-V-US related_to CASE-CARPENTER-V-US.

Sources

  1. SRC-CHATRIE-LII: Chatrie v. United States, No. 25-112 (June 29, 2026) (Cornell LII).
  2. SRC-CARPENTER-LII: Carpenter v. United States, 585 U.S. 296 (2018) (Cornell LII).
  3. SRC-HILL-MARLOW-REVERSE-WARRANTS-2026: The Hill — Chad Marlow Opinion on Reverse Warrants / Chatrie (July 30, 2026).

Additional sources (not yet cited in footnotes):

Research Debt

  • Add Justia / United States Reports citation once official reporter pagination is available.
  • Intake Delaware reverse-keyword-warrant bill text (bill number, enactment/signing status) before stating Delaware law as enacted fact beyond Marlow’s attributed description.
  • Consider PERSON page for Chad Marlow with official ACLU bio source.
  • Cross-link Fourth Amendment Is Not For Sale Act source records on this page once policy crosswalk is drafted.
  • Domain expert review of geofence-warrant particularity literature before status above draft.
  • Note: offense_date is the underlying May 20, 2019 robbery date from the Supreme Court syllabus (investigative context), not a finding that Chatrie committed the robbery.

Document metadata

  • Decision date: 2026-06-29
  • Offense date: 2019-05-20
  • Last verified: 2026-07-30

  1. SRC-CHATRIE-LII — Chatrie v. United States, No. 25-112 (June 29, 2026) (Cornell LII). Primary authority (syllabus/opinion). ↩↩↩↩↩↩↩↩

  2. SRC-CARPENTER-LII — Carpenter v. United States, 585 U.S. 296 (2018) (Cornell LII). Primary authority. ↩

  3. SRC-HILL-MARLOW-REVERSE-WARRANTS-2026 — The Hill — Chad Marlow Opinion on Reverse Warrants / Chatrie (July 30, 2026). Opinion/advocacy commentary. ↩↩