Key Takeaway: In Chatrie v. United States, the United States Supreme Court held that police conduct a Fourth Amendment search when they obtain a person’s Google Location History through a geofence warrant. This decision gives defendants a stronger basis to challenge cell phone location evidence in federal criminal cases and Pennsylvania criminal cases involving digital surveillance. 

Chatrie v. United States: Details of the Case

Chatrie v. United States arose from a 2019 credit union robbery in Midlothian, Virginia. Investigators reviewed witness statements and surveillance footage and learned that the robber appeared to approach the credit union while using a cell phone. Unable to identify a suspect through traditional investigative methods, police applied for a geofence warrant directed to Google. 

A geofence warrant works differently from a traditional search warrant. Instead of starting with a known suspect, police draw a virtual boundary around a place and time connected to a crime, then ask a technology company to identify devices located within that area. In this case, the warrant sought Google Location History data for devices within a 150-meter radius of the credit union during a one-hour window around the robbery. 

The warrant used a three-step process:

1. Google would provide anonymized location data for devices inside the geofence.
2. Police would review that data and request additional anonymized location information for a narrowed list of users, including movements inside and outside the geofence.
3. Google would provide identifying information, such as names and phone numbers, for selected users.

Through this process, Google identified three users, including Okello Chatrie. Chatrie was later charged by a federal grand jury with robbery and related firearms offenses.

He filed a motion to suppress the Google Location History evidence, arguing that police obtained it through an unconstitutional search. 

The Issue on Appeal

The central issue before the Supreme Court was whether police violate the Fourth Amendment when they obtain a person’s Google Location History data from Google through a geofence warrant.

That question matters because Location History can reveal highly personal information. The Supreme Court described Google Location History as a time-stamped record of where a cell phone has been, drawing on sources such as Wi-Fi, Bluetooth, cell sites, GPS, and IP address information. The Court noted that this data can locate a phone within about 20 meters and can sometimes reveal elevation, including which floor of a building the phone is on. 

For defendants, the legal question was straightforward but powerful: Does the government need to satisfy Fourth Amendment protections before accessing this kind of digital location evidence?

Why the Supreme Court Agreed to Hear the Case

The lower courts had split over how to treat geofence warrants and Google Location History under the Fourth Amendment.

The federal district court agreed with much of Chatrie’s Fourth Amendment argument and found the particular geofence warrant problematic, but it still allowed the evidence under the good-faith exception to the exclusionary rule. The Fourth Circuit initially affirmed on different grounds, reasoning that Chatrie did not have a reasonable expectation of privacy in two hours of Location History data voluntarily exposed to Google. The Fourth Circuit later reheard the case en banc and divided evenly on whether a Fourth Amendment search occurred. 

The Supreme Court agreed to review the case to decide whether police conducted a Fourth Amendment search when they obtained Chatrie’s Google Location History. The Court granted review only on that search question, not on whether the evidence must ultimately be suppressed under the good-faith exception. 

Understanding the Supreme Court’s Chatrie  Decision

The Supreme Court held that police do conduct a Fourth Amendment search when they access Google Location History data. The Court explained that people have a reasonable expectation of privacy in records revealing their cell phone’s location, even when the government obtains those records from a third-party technology company and even when the time period is limited. 

This is a major Fourth Amendment ruling for digital privacy. The Court rejected the idea that users lose constitutional protection simply because Google stores the data. In practical terms, the government cannot avoid the Fourth Amendment by saying that the data came from a technology company instead of directly from a defendant’s phone. 

The Court Did Not Automatically Suppress the Evidence

The ruling is important, but it does not mean every geofence warrant is automatically unconstitutional or that every defendant will automatically win suppression.

The Supreme Court left key questions for the Fourth Circuit to decide on remand, including whether each step of the warrant satisfied the Fourth Amendment’s probable cause and particularity requirements. The Court also left the good-faith exception issue for further review. 

That distinction matters for defendants. Chatrie gives defense attorneys a stronger constitutional argument, but the outcome of a motion to suppress will still depend on the facts of the case, the warrant language, the scope of the search, and whether prosecutors argue that officers relied on the warrant in good faith.

How Chatrie  Builds on Carpenter v. United States

The Supreme Court’s reasoning in Chatrie builds on Carpenter v. United States, the landmark case holding that accessing historical cell-site location information is a Fourth Amendment search. In Chatrie, the Court found that Google Location History raises the same privacy concerns, and in some ways greater concerns, because it can be more precise and more revealing than traditional cell-site location information. 

The Court emphasized that modern smartphones are deeply woven into daily life. Because Location History can track a person’s movements through private and sensitive places, it can reveal far more than whether someone was near a public street or business. The Court recognized that this type of data can function like a detailed timeline of a person’s movements. 

Why the Third-Party Doctrine Did Not Save the Government

The government argued that Chatrie had no Fourth Amendment claim because he had shared his location data with Google. The Supreme Court rejected that argument.

The Court explained that ordinary smartphone use should not be treated as giving the government free access to private location records. In the Court’s words, a cell phone user should not be viewed as sharing private information with third parties simply by doing the ordinary things cell phone users do. 

What Does Chatrie  Mean for Defendants in Pennsylvania?

For defendants in Pennsylvania, including Philadelphia, Montgomery County, Delaware County, Chester County, and the surrounding region, Chatrie is a significant decision in cases involving geofence warrants, Google Location History, cell phone location data, and digital surveillance.

If police used a geofence warrant or similar digital location tool in your case, a criminal defense attorney should carefully review:

 1. Whether the Search Was Supported by Probable Cause

The warrant must be based on a fair probability that evidence of a crime will be found in the place searched. In geofence cases, that means prosecutors may need to justify why location data from that area and time period would identify a suspect, accomplice, witness, or other relevant evidence.

2. Whether the Warrant Was Narrow Enough

The Fourth Amendment requires particularity. That means the warrant must be limited in scope and carefully tied to its justification. In geofence warrant cases, important details may include the size of the geographic area, the time window, the number of devices captured, and whether police had too much discretion to expand the search.

3. Whether Police Followed the Warrant’s Limits

A warrant may appear narrow on paper but operate broadly in practice. Defense counsel should examine each stage of the process, including how police narrowed the list of devices, whether the warrant gave officers too much discretion, and whether identifying information was requested for people without individualized probable cause.

4. Whether the Good-Faith Exception Applies

Even if a warrant is defective, prosecutors may argue that the evidence should still be admitted because officers relied on the warrant in good faith. The Supreme Court did not decide that issue in Chatrie, which means it remains a key battleground in future suppression litigation.

Can Cell Phone Location Evidence Be Challenged After Chatrie?

Yes. Chatrie gives defendants a stronger foundation for challenging government access to Google Location History and similar digital location evidence. That does not mean every challenge will succeed, but it does mean courts must treat this kind of data as protected by the Fourth Amendment.

A motion to suppress may be appropriate when the government used:

1. Geofence Warrants

These warrants may sweep in location data from many people who were near a place but were not suspected of any crime.

2. Google Location history

This data can reveal where a person went, when they were there, and potentially whether they entered private or sensitive spaces.

3. Cell Phone Location Data

Digital location evidence may include Google data, cell-site location information, app-based data, or other records that track a person’s movements.

4. Broad Digital Warrants

The broader the search area, the longer the time window, and the more discretion police have, the more important it becomes to challenge whether the warrant satisfied the Fourth Amendment.

Why This Decision Matters for Criminal Defense

Digital evidence is now common in federal and Pennsylvania criminal cases. Prosecutors may rely on cell phone location records in robbery cases, drug investigations, firearm cases, conspiracy cases, homicide cases, and other serious charges.

Chatrie confirms that constitutional rights still apply when police use modern technology. The government may have powerful tools, but it must still respect the Fourth Amendment.

For defendants, that means digital evidence should never be accepted at face value. It should be tested, challenged, and reviewed by an experienced criminal defense lawyer.

Speak With a Pennsylvania Criminal Defense Attorney About Digital Evidence

If you or a loved one is facing criminal charges in Pennsylvania and the government is relying on geofence warrant evidence, Google Location History, cell phone tracking, or other digital surveillance, the details matter.

A strong defense may begin with asking whether the government had probable cause, whether the warrant was too broad, whether innocent people were swept into the search, whether police exceeded the warrant’s limits, and whether the evidence should be suppressed.

The Law Office of John F. McCaul represents people facing serious criminal charges in Pennsylvania and federal court. If digital evidence is part of your case, an experienced defense attorney can review the warrant, analyze the government’s methods, and protect your constitutional rights.

Request a free and confidential consultation with the Law Office of John F. McCaul.

Frequently Asked Questions About Chatrie v. United States