Facts of the Case
Investigating a 2019 armed robbery of a Richmond-area credit union, police obtained a geofence warrant compelling Google to produce location data for every device within a 150-meter radius of the bank during a one-hour window, an area that also swept in homes, a church, a hotel, and public streets. Follow-up requests for expanded movement data and account-identifying information led investigators to Okello Chatrie, who was charged federally and moved to suppress the location evidence. The district court found the warrant likely defective but applied the good-faith exception, and the en banc Fourth Circuit affirmed the denial of suppression.
Questions
Did the execution of the geofence warrant violate the Fourth Amendment?
Conclusions
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On June 29, 2026, the U.S. Supreme Court held 5-4 in Chatrie v. United States that compelling a technology company to produce location data for all devices within a geofence is a Fourth Amendment search, requiring a warrant supported by probable cause and particularity.