Geofence Warrants
Rulings about warrants that ask a company such as Google for location data on every device inside a set area during a set time. Summaries from Criminal Defense Resources™ are general education for pro per/pro se defendants and families, not legal advice.
4 rulings, newest first.
Chatrie v. United States
The Court held that police conducted a Fourth Amendment search when they obtained a person's Google Location History data through a geofence warrant, because people have a reasonable expectation of privacy in their cell-phone location information. The Court did not decide whether this particular multi-step warrant was valid; it vacated the Fourth Circuit's decision and sent the case back for that court to decide.
United States v. Chatrie
The full Fourth Circuit affirmed the conviction in a one-sentence unsigned opinion. The judges were evenly divided on whether obtaining the geofence data was a Fourth Amendment search. The U.S. Supreme Court later vacated this decision in Chatrie v. United States (2026).
United States v. Smith
The Fifth Circuit held that geofence warrants are modern-day general warrants that violate the Fourth Amendment. But it did not suppress the evidence in that case, because officers relied in good faith on the warrant.
United States v. Chatrie
A divided Fourth Circuit panel held that no search occurred because the defendant did not have a reasonable expectation of privacy in two hours of Location History data he had voluntarily shared with Google. The full court later reheard the case.
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