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The Supreme Court heard oral arguments on April 27 in Chatrie v. United States, the first geofence warrant case the justices have taken directly. A decision is expected before the term ends.
The case asks the Court to decide whether a single category of digital search is consistent with the Fourth Amendment. The stakes cut both ways. Geofence warrants gave investigators a way to identify suspects in cases that had no leads, from the January 6 riot at the U.S. Capitol to homicides, postal robberies and arsons. Privacy groups argue the same warrants sweep up every phone in a defined area, suspect or not, and look more like the general searches the Fourth Amendment was written to prevent. The justices are weighing one against the other.
A geofence warrant is a court order that asks a company, almost always Google in the cases that produced this body of law, to identify every device whose location data placed it inside a defined area during a defined window. The government has no suspect when it applies. The technique is supposed to produce one.
What makes the Chatrie case unusual is that the technique no longer functions the way it did when the warrant in question was issued. Google answered more than 20,000 of these warrants between 2018 and 2020. By July 2025, the company had finished moving Location History off its servers and onto users' phones. The pipeline that produced the warrants is closed.
Here is what the tool was, why some courts believe it violates the Constitution, and where the data went.
A traditional search warrant names a suspect or a place. The government has probable cause that a person committed a crime, and the warrant authorizes a search of that person's home, car or accounts.
A geofence warrant works the other direction. The government has a location and a time window. It asks Google to identify every device whose Location History placed it inside that area during that window. Google runs the query and returns anonymized device IDs. The government narrows the list and asks Google to de-anonymize a handful.
The data is generated by Google Location History, the opt-in feature most people associate with Google Maps. Pre-cutover, that data could place a device within meters of its actual location at frequent intervals. That is closer to a GPS tracker than the cell tower data the Supreme Court ruled on in Carpenter v. United States in 2018.
The Fourth Amendment bars unreasonable searches and seizures and requires warrants to be supported by probable cause and to particularly describe the place to be searched and the things to be seized. A geofence warrant does neither in the traditional sense. It searches every device in a defined area, not a named suspect, and the people the warrant catches are unknown when it is issued. Critics argue that is closer to a general warrant, the practice the Fourth Amendment was written against, than to a particular one.
Carpenter is the precedent that hangs over the case. In 2018 the Supreme Court ruled that the government needed a warrant to obtain seven days of cell-site location records from a wireless carrier, holding that the third-party doctrine did not strip Fourth Amendment protection from "an exhaustive chronicle of location information." Geofence data is more precise than cell-site data and pulled from a wider base of users. The question in Chatrie is how far Carpenter reaches.
Geofence warrants moved from rare to routine fast. Google disclosed for the first time in 2021 that it had received 982 geofence warrants in 2018, 8,396 in 2019, and 11,554 in 2020. The 2020 total alone averaged more than 30 warrants per day.
The named cases span every type of investigation. Investigators used geofence warrants in postal robberies, in arson cases, homicides and in missing person searches. The largest single deployment was January 6. The FBI's geofence warrant for a four-acre area around the Capitol on the afternoon of the riot returned 5,723 devices in Google's initial sweep. Geofence data ran through many of the prosecutions that followed.
The technique was attractive precisely because it inverted the warrant process. A traditional warrant requires a suspect. A geofence warrant produces one.
In December 2023, Google announced that Location History would be saved locally on users' devices instead of in their Google accounts, with the new feature renamed Timeline inside Google Maps. The default retention period dropped from 18 months to three. The rollout proceeded gradually and was fully in place by July 2025. I wrote about this earlier as Google was finalizing it, and the operative point then is the same now: once the data sits on the device, Google has no database to search.
The Electronic Frontier Foundation, which has tracked geofence litigation across multiple circuits, made the same point. Once Google moved the data on-device, the company could no longer respond.
The other reason geofence warrants were a Google story is Apple. Investigators send geofence requests to Apple too. Apple just has nothing to hand over. The company's Legal Process Guidelines state that "device location services information is stored on each individual device and Apple cannot retrieve this information from any specific device." Apple confirmed the same point publicly when it disclosed in its 2023 transparency report that it had received geofence requests but had no data to provide in response. Apple's architecture has always kept location data on the device. Google has now joined them.
In May 2019, a man robbed the Call Federal Credit Union in Midlothian, Virginia at gunpoint and left with $195,000. The investigation stalled. The lead detective applied for a geofence warrant directing Google to produce Location History records for every device inside a 150-meter radius around the credit union for an hour bracketing the robbery. The 150-meter radius produces a 300-meter diameter, longer than three football fields. The area included a church, a hotel, a restaurant and a senior center.
Google's response proceeded in three stages. Step one returned anonymized data on every device inside the geofence. Step two narrowed the list. Step three de-anonymized three devices and returned subscriber information. One was Okello Chatrie. He entered a conditional guilty plea preserving his right to challenge the warrant and was sentenced to roughly 12 years.
Two federal appeals courts have already split on whether the warrant was constitutional. The full Fourth Circuit deadlocked 7-7 on whether a Fourth Amendment search had even happened, produced nine separate opinions across 126 pages, and affirmed Chatrie's conviction in a single sentence. The Fifth Circuit looked at the same kind of warrant in United States v. Smith and ruled that geofence warrants violate the Fourth Amendment categorically as "general, exploratory rummaging" through every device in an area. That circuit split is what the Supreme Court took up. The cert grant is narrow. The justices are evaluating this one warrant on this one set of facts, not whether geofence warrants are categorically banned.
A ruling is expected before the term ends. Whatever the justices decide, it will not bring the geofence warrant back the way it worked between 2018 and 2024. Google does not hold the data anymore. Apple never did.
What the ruling will do is decide whether the warrants Google answered during those years were constitutional in the first place. That still matters for any case that relied on geofence data and is still on appeal. Chatrie is the last major case of its kind from the Google geofence era. The decision in it will be the only Supreme Court word on the technique, on a tool the companies that ran it have already turned off.
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