Yes. In Chatrie v. United States, decided June 29, 2026, the United States Supreme Court held that police conduct a Fourth Amendment search when they obtain a person’s Google Location History data. That means the government generally needs a real warrant supported by probable cause.
What is a geofence warrant?
A geofence warrant is a search warrant aimed at a place, not a person.
With a normal warrant, police usually identify a suspect first. Then they ask a judge for permission to search that person, home, car, phone, or account.
A geofence warrant works differently. Police draw a virtual circle around a location. Then they ask a technology company, often Google, to identify phones that were inside that area during a certain time.
That means the search may collect data from:
- The suspect
- Witnesses
- Employees
- Customers
- People walking nearby
- People visiting private places near the scene
This is why geofence warrants raise serious privacy concerns.
What happened in Chatrie v. United States?
The case started with a 2019 credit union robbery in Midlothian, Virginia.
Police had limited evidence. Witnesses and surveillance footage suggested the robber appeared to be using a cell phone. Investigators then sought a geofence warrant directed at Google.
The warrant covered a 150-meter radius around the credit union. Google was ordered to provide Location History data for phones inside that area around the time of the robbery.
The process had three steps:
- Google produced anonymized location data for 19 phones.
- Police narrowed the list and received more location data for nine phones.
- Police narrowed the list again and received identifying information for three users.
One of those users was Okello Chatrie. His data allegedly showed that he entered the area before the robbery and left afterward. He was later charged with robbery and firearm offenses.
What did the Supreme Court decide about phone location data?
The Supreme Court held that police searched Chatrie when they obtained his Location History data from Google.
The Court relied heavily on Carpenter v. United States, 585 U.S. 296 (2018). In Carpenter, the Court held that police generally need a warrant to obtain historical cell-site location information.
The Court said Location History can be even more revealing than cell tower data. Google Location History may record a phone’s location every two minutes. It can place a phone within about 20 meters. It may also show elevation, including which floor of a building the phone was on.
In plain English, phone data can reveal far more than a person’s general location. It can show visits to homes, doctors, lawyers, churches, schools, hospitals, political meetings, and other sensitive places.
Does it matter that the police only requested two hours of data?
No. The Supreme Court rejected the idea that short-term tracking gets a constitutional free pass.
The government argued that two hours of location data was not enough to trigger Fourth Amendment protection. The Court disagreed.
The Fourth Amendment does not have a grace period. If accessing the data is a search, it is a search whether the government obtains two hours, two days, or much more.
That point matters in Indianapolis, Westfield, and across Indiana. A person can become part of an investigation because a phone was near a crime scene for a brief window of time.
That does not mean the person committed a crime. It may only mean the person was nearby.
Does sharing location data with Google eliminate privacy rights?
No. The Court rejected the government’s third-party doctrine argument.
The third-party doctrine usually says that people have less privacy in information they voluntarily share with a company. The government argued that Chatrie shared his location with Google, so he had no Fourth Amendment protection.
The Supreme Court disagreed.
The Court explained that modern smartphone use is not the same as knowingly handing private information to another person. People use smartphones for maps, email, photos, calendars, rides, weather, food apps, and daily life. They do not give up constitutional rights simply by using ordinary phone features.
Did the Supreme Court throw out Chatrie’s conviction?
No. This is important.
The Supreme Court did not decide whether Chatrie walks free. It did not decide whether the geofence warrant was valid at every step. It also did not decide whether the good-faith exception still allows the evidence to be used.
Instead, the Court sent the case back to the Fourth Circuit.
The remaining issue is whether the warrant satisfied the Fourth Amendment’s requirements of probable cause and particularity.
Probable cause means there must be a fair probability that evidence of a crime will be found.
Particularity means the warrant must clearly limit what police can search and seize. It cannot become a broad fishing expedition.
Can police still use geofence warrants after Chatrie?
Yes, but the Constitution now clearly applies when police obtain Location History data.
The ruling does not ban all geofence warrants. It also does not prevent police from acting in a true emergency. Courts have long recognized emergency exceptions to the warrant requirement in limited circumstances.
But after Chatrie, police cannot treat Google Location History as constitutionally unprotected simply because it is held by a tech company.
For criminal cases in Indiana, this may matter when prosecutors rely on:
- Google Location History
- Cell phone movement data
- App-based location records
- Reverse-location searches
- Warrants that identify people based on proximity to a crime scene
Defense lawyers should closely review how the data was obtained.
What should I do if police say my phone was near a crime scene?
Do not guess. Do not explain. Do not try to talk your way out of it.
A person can be innocent and still say something that creates problems. Location data may be incomplete, misleading, or taken out of context.
If police come to your door, you have rights. You can be polite and still protect yourself.
A simple response is:
“I am not going to answer questions. I want to speak with a lawyer.”
Then stop talking.
You do not have to explain why you were nearby. You do not have to discuss a doctor’s visit, a private meeting, or where you were going. Those details may be personal. They may also become evidence.
Why does this case matter for people in Indiana?
Phone location evidence is becoming common in criminal investigations. It can appear in robbery, drug, gun, theft, battery, and homicide cases.
In Indianapolis, Marion County, Hamilton County, and surrounding Indiana courts, digital evidence can shape how a case is charged and defended.
The key lesson from Chatrie is simple: your phone’s location history is not open season for the government. When police obtain that information from a tech company, the Fourth Amendment applies.
That does not automatically win a case. But it creates a real legal issue. The warrant, probable cause, scope, timing, and police procedures all matter.
Talk to an Indiana Criminal Defense Lawyer
If police are asking questions about your phone, your location, or why you were near a particular place, speak with a lawyer before making a statement.
The Marc Lopez Law Firm represents people facing criminal charges in Indianapolis, Hamilton County, and throughout Central Indiana. If you or a loved one are facing criminal charges give us a call at 317-632-3642.
FAQ: Phone Location Data, Geofence Warrants, and Your Rights
Do police need a warrant to get my phone location data?
Yes, generally. In Chatrie v. United States, the Supreme Court held that police conduct a Fourth Amendment search when they obtain Google Location History data. That means the government usually needs a warrant supported by probable cause.
What is a geofence warrant?
A geofence warrant asks a technology company to identify phones located inside a specific area during a specific time. Police use it when they know where a crime happened but do not yet know who committed it.
Can I become a suspect just because my phone was near a crime scene?
Yes. A geofence search can identify people whose phones were near a crime scene. That does not mean the person committed a crime. It may only mean the person was nearby.
Does Google Location History show exactly where I was?
It can be very precise. The Supreme Court noted that Google Location History may record location about every two minutes and may place a phone within about 20 meters. In some situations, it may even show elevation, including which floor of a building the phone was on.
Did the Supreme Court ban geofence warrants?
No. The Court did not ban all geofence warrants. It held that obtaining Location History data is a Fourth Amendment search. Courts still must decide whether a specific warrant satisfies probable cause, particularity, and other constitutional requirements.
Does the Chatrie case apply in Indiana?
Yes, as a United States Supreme Court decision, Chatrie applies nationwide, including Indiana. It may affect criminal cases in Indianapolis, Westfield, Marion County, Hamilton County, and other Indiana courts when prosecutors use phone location evidence.
What should I say if police ask about where my phone was?
A safe response is: “I am not going to answer questions. I want to speak with a lawyer.” Then stop talking. A person can be innocent and still create problems by trying to explain location data without legal advice.
Can police still get phone location data in an emergency?
Sometimes. Courts recognize limited emergency exceptions to the warrant requirement. But outside a true emergency, police generally need to follow the Fourth Amendment before obtaining protected location data.
Can phone location evidence be challenged in court?
Yes. A defense lawyer may challenge whether the warrant had probable cause, whether it was specific enough, whether the search went too far, and whether police followed the warrant’s limits.
Should I talk to a lawyer if police say my phone was near a crime?
Yes. Phone location evidence can be misunderstood or taken out of context. If police are asking about your location, your phone, or why you were near a certain place, speak with a criminal defense lawyer before answering questions.
Give us a call at 317-632-3642 and remember, always plead the Fifth.