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Chatrie v. United States: What the Geofence Ruling Does and Does Not Decide

On 29 June 2026 the Supreme Court decided Chatrie v. United States, No. 25-112. Police investigating a 2019 credit union robbery in Midlothian, Virginia obtained a geofence warrant directing Google to hand over data on phones within a 150-metre radius near the time of the crime. Google's Location History records a phone's position about every two minutes.

The holding is narrow and worth quoting: police "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". That is the whole of it. Justice Kagan wrote for the Court, joined by the Chief Justice and Justices Sotomayor, Kavanaugh and Jackson.

├─◊RecordedDecided

29 Jun 2026

├─◊RecordedDocket

No. 25-112

├─◊RecordedQuestion decided

Search: yes

└─◊RecordedWarrant standard set

Not decided

What the Court left open

The opinion is explicit about its own limits. Answering the question in full would mean deciding both whether a search occurred and whether that search was reasonable given the warrant used. In the Court's words, "We decide the first part of that inquiry today." The judgment below was vacated and remanded, leaving the Fourth Circuit to decide whether the warrant met the requirements of particularity and probable cause at each step.

The Court also did not address whether the good-faith exception to the exclusionary rule still allows the data to be admitted. The District Court had already found the warrant violated the Fourth Amendment but declined to suppress on that basis. So this ruling does not, on its own, throw out the evidence.

The Court was not unanimous. Justice Gorsuch concurred in the judgment only. Justice Alito dissented, joined in part by Justices Thomas and Barrett, and Justice Barrett filed a separate dissent.

The license plate question

Reporting after the decision raised whether automated license plate readers, or ALPRs, are affected. The honest answer is that the opinion does not say. The words "license plate" and "automated" do not appear in it. Chatrie is about phone location records held by Google.

The passage most often cited in that debate concerns United States v. Knotts. The Court explains that Knotts is a poor fit partly because the surveillance there "was confined to public roads", and that under Knotts "[a] person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy". It then draws the contrast: "the movements that Location History reveals are not limited to public streets".

That reasoning cuts both ways. It is the basis for arguing that a database revealing a person's movements deserves protection regardless of the technology. It is also the distinction ALPR vendors point to, because plate cameras capture vehicles in public view rather than following a person indoors. Which reading prevails is a question for later litigation, not something Chatrie settles.

What holds regardless

Plate cameras keep operating on their existing legal footing until a court says otherwise. The Electronic Frontier Foundation records the mechanics that do not change with this ruling: fixed and vehicle-mounted cameras capture every plate in view along with location, date and time; the records are uploaded centrally and often shared across many agencies; and agencies pre-load hot lists that trigger alerts on a match. EFF cites California data showing 0.05 percent of collected ALPR records were relevant to a public safety interest when captured.

Retention is the part that decides how revealing the system is. A record discarded when no hot list match occurs reveals little. Records held for long periods build travel patterns. Those are set by agency policy and state law, not by this decision.

For how these deployments are structured and what to request from an agency, see Flock Safety expansion.

Status

Decided and binding as to its holding. The reasonableness of the warrant is back before the Fourth Circuit and unresolved as of 6 August 2026. No court has extended Chatrie to license plate readers. Claims that plate reader searches now require a warrant are not supported by the text of the opinion.