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Chatrie v. United States
Opinion: https://www.supremecourt.gov/opinions/25pdf/25-112_0am4.pdf
Case background
In 2019, a man robbed a credit union in Midlothian, Virginia. Local police
could not identify a suspect, so they obtained a geofence warrant directed to
Google, requiring the company to hand over data about the cell phones located
within a 150-meter radius of the credit union near the time of the crime.
That data came from Location History, a Google service that records a user’s
cell-phone location every two minutes or so. The warrant set out a three-step
process: Google first produced anonymized location data for all phones inside
the geofence in the half hour before and after the robbery; officers then
narrowed the list and Google supplied additional anonymized data covering a
two-hour window; and finally officers narrowed the list again and Google
turned over identifying information, including names and phone numbers. That
process identified three users, including petitioner Okello Chatrie, whose
data showed him entering the geofence about ten minutes before the robbery.
Chatrie, charged with robbery and related firearms offenses, moved to suppress
the location data as the fruit of an invalid Fourth Amendment search. The
District Court found the warrant violated the Fourth Amendment but denied
suppression under the good-faith exception to the exclusionary rule, and after
a divided panel and an evenly divided en banc court, the Fourth Circuit
affirmed. The Supreme Court granted certiorari solely on whether the police
violated the Fourth Amendment in obtaining Chatrie’s location data.
Questions Presented
(1) Whether the execution of the geofence warrant violated the Fourth Amendment.
Holding
Police officers 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. Everything the
Court relied on in Carpenter v. United States to hold that accessing cell-site
location information is a search applies as well or better to Location History,
which is even more precise and revealing. Neither the limited two-hour period
of data obtained nor its storage by a third-party company defeats that
expectation of privacy, and the third-party doctrine does not apply. Because
the Fourth Amendment prohibits only unreasonable searches, the Court does not
decide whether this search was reasonable, leaving to the Court of Appeals
whether, at each step of the search process, the warrant satisfied the Fourth
Amendment’s requirements of probable cause and particularity.
The Court
Justice Kagan delivered the opinion of the Court, in which Chief Justice
Roberts and Justices Sotomayor, Kavanaugh, and Jackson joined. Justice Jackson
filed a concurring opinion, in which Justice Sotomayor joined. Justice Gorsuch
filed an opinion concurring in the judgment. Justice Alito filed a dissenting
opinion, in which Justice Thomas joined as to Part I, and in which Justice
Barrett joined as to Parts II–B, II–C–1, and II–C–2. Justice Barrett filed a
dissenting opinion.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Chatrie v. United States, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.
View all episodes
By So OrderedOpinion: https://www.supremecourt.gov/opinions/25pdf/25-112_0am4.pdf
Case background
In 2019, a man robbed a credit union in Midlothian, Virginia. Local police
could not identify a suspect, so they obtained a geofence warrant directed to
Google, requiring the company to hand over data about the cell phones located
within a 150-meter radius of the credit union near the time of the crime.
That data came from Location History, a Google service that records a user’s
cell-phone location every two minutes or so. The warrant set out a three-step
process: Google first produced anonymized location data for all phones inside
the geofence in the half hour before and after the robbery; officers then
narrowed the list and Google supplied additional anonymized data covering a
two-hour window; and finally officers narrowed the list again and Google
turned over identifying information, including names and phone numbers. That
process identified three users, including petitioner Okello Chatrie, whose
data showed him entering the geofence about ten minutes before the robbery.
Chatrie, charged with robbery and related firearms offenses, moved to suppress
the location data as the fruit of an invalid Fourth Amendment search. The
District Court found the warrant violated the Fourth Amendment but denied
suppression under the good-faith exception to the exclusionary rule, and after
a divided panel and an evenly divided en banc court, the Fourth Circuit
affirmed. The Supreme Court granted certiorari solely on whether the police
violated the Fourth Amendment in obtaining Chatrie’s location data.
Questions Presented
(1) Whether the execution of the geofence warrant violated the Fourth Amendment.
Holding
Police officers 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. Everything the
Court relied on in Carpenter v. United States to hold that accessing cell-site
location information is a search applies as well or better to Location History,
which is even more precise and revealing. Neither the limited two-hour period
of data obtained nor its storage by a third-party company defeats that
expectation of privacy, and the third-party doctrine does not apply. Because
the Fourth Amendment prohibits only unreasonable searches, the Court does not
decide whether this search was reasonable, leaving to the Court of Appeals
whether, at each step of the search process, the warrant satisfied the Fourth
Amendment’s requirements of probable cause and particularity.
The Court
Justice Kagan delivered the opinion of the Court, in which Chief Justice
Roberts and Justices Sotomayor, Kavanaugh, and Jackson joined. Justice Jackson
filed a concurring opinion, in which Justice Sotomayor joined. Justice Gorsuch
filed an opinion concurring in the judgment. Justice Alito filed a dissenting
opinion, in which Justice Thomas joined as to Part I, and in which Justice
Barrett joined as to Parts II–B, II–C–1, and II–C–2. Justice Barrett filed a
dissenting opinion.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Chatrie v. United States, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.