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Chatrie sits at the intersection of those precedents, raising the question whether sweeping geofence warrants fit within existing doctrine, or represent something fundamentally different in scope and scale.

More recently, in Carpenter v. United States (2018), the Court limited that principle, holding that individuals retain a reasonable expectation of privacy in historical cell-site location data, even when held by third parties.

This Doctrine can be traced back to cases like Katz v. United States (1967), where the Court held the Fourth Amendment protects reasonable expectations of privacy, but not information knowingly exposed to others. Watch a FedSoc Film on the Katz v. United States decision:

The government, by contrast, argues no “search” occurred. It contends that the users covered by the warrant voluntarily shared location data with companies like Google, an argument that is rooted in the Third-Party Doctrine.

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