No legal advice and no prediction stated as fact. Where a decision does not reach ALPR, this file says so plainly rather than implying a result.
Chatrie v. United States
Supreme Court of the United States · No. 25-112
DOES NOT MENTION ALPR
- ARGUED
- 2026-04-27
- DECIDED
- 2026-06-29
- DISPOSITION
- 136 F. 4th 100, vacated and remanded.
- LAST VERIFIED
- 2026-08-07
Police obtained a geofence warrant directed to Google after a 2019 credit union robbery in Midlothian, Virginia. The warrant covered a 150-metre radius and ran a three-step narrowing process, at one stage producing location data across a two-hour window. Nineteen users were returned at step one, narrowed to nine, then to three, of whom Chatrie was one.
HELD
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.
WHO DECIDED IT
KAGAN, J. delivered the opinion of the Court, joined by ROBERTS, C. J., SOTOMAYOR, KAVANAUGH, and JACKSON, JJ. JACKSON, J. filed a concurring opinion, joined by SOTOMAYOR, J. GORSUCH, J. filed an opinion concurring in the judgment. ALITO, J. filed a dissenting opinion, joined by THOMAS, J. as to Part I and by BARRETT, J. as to Parts II-B, II-C-1, and II-C-2. BARRETT, J. filed a dissenting opinion.
WHAT IT SETTLES
- Acquiring a person's cell-phone location history is a Fourth Amendment search, so it needs a warrant or a recognised exception.
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.
Syllabus, Held - A short window of tracking is not automatically outside the Fourth Amendment. The two-hour extended window here was still a search.
the movements that Location History reveals are not limited to public streets
Opinion of the Court, discussing Knotts
WHAT IT DOES NOT SETTLE
- Whether the evidence is admissible anyway. The Court expressly declined to reach the good-faith exception and sent it back.
In line with our grant of certiorari, we do not address whether the good-faith exception to the exclusionary rule still allows the admission of the Location History data in this case. That question remains for the Fourth Circuit to consider anew.
Opinion of the Court, n. 4 - Anything about automated licence plate readers. No ALPR question was presented, briefed, or decided.Absence of any reference in the opinion
HOW FAR IT CARRIES TO PLATE READERS
The decision is about a phone that travels with a person into private space. A fixed ALPR photographs a vehicle on a public road. The opinion's own reasoning points in both directions on whether that difference matters, and it did not resolve it.
The words automated licence plate reader, licence plate, plate reader, and ALPR do not appear anywhere in the opinion. This was checked by searching the full text of the slip opinion, not inferred from summaries.
CUTS AGAINST READING IT ACROSS
- The Court distinguished Knotts partly because the surveillance in that case stayed on public roads, and quoted Knotts approvingly on the point. That is the side of the line a fixed roadside camera sits on.
And still another feature of Knotts makes it inapt here: that the surveillance there was confined to public roads. That fact was crucial to the Court's decision: "A person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy," Knotts explained, because the car is always "in plain view."
Opinion of the Court, discussing United States v. Knotts, 460 U. S. 276, 281 (1983) - What made Location History different, on the Court's account, was that it follows a person off the road and indoors. A plate reader does not do that.
A "cell phone faithfully follows its owner beyond public thoroughfares and into private residences, doctor's offices, [and] political headquarters."
Opinion of the Court, quoting Carpenter v. United States, 585 U. S. 296, 311 (2018)
CUTS TOWARD READING IT ACROSS
- The Court treated comprehensiveness rather than duration as the thing that matters, and rejected the argument that a short window is categorically safe. A dense, networked, nationally searchable camera system is an argument about comprehensiveness.
Knotts "was careful to distinguish between the rudimentary tracking facilitated by the beeper and more sweeping modes of surveillance"
Opinion of the Court, quoting Carpenter, 585 U. S., at 306-307
WHERE THAT LEAVES IT
Chatrie does not decide the ALPR question either way. Anyone citing it as authority that plate readers require a warrant is overreading it, and the Knotts passage is the part they are leaving out. Anyone citing it as authority that plate readers are fine is also overreading it, because the Court's stated concern was the reach of the whole system rather than any single observation.
