Geofence Warrants Explained - Chatrie v. United States
Elif Painaik, Co-Editor in Chief
Overview
In Chatrie vs. United States, the Supreme Court is currently considering whether the execution of a geofence warrant violated the Fourth Amendment.¹ A geofence warrant is a legal court order that compels technology companies to provide data on every electronic device present within a specific geographic area during a designated time frame. This allows police to scan thousands of devices, even those of innocent bystanders. Unlike traditional warrants that target a specific, known suspect, police use geofence warrants when the perpetrator's identity is initially unknown.² Okello Chatrie, the petitioner who was convicted partially based on one of these warrants, is arguing that these warrants violated his Fourth Amendment right to unreasonable search and seizure and impeded on privacy.
Significance
With rapid technological developments such as geofencing, questions of privacy are increasingly relevant to the Supreme Court and to the legal system as a whole, and more specific legislative regulation is needed to ensure that law enforcement does not use technology to violate constitutional rights. Warrants such as these often turn
innocent passersby into suspects, and Harvard Law Review writes that they have effectively “obliterated the utility of probable cause as a meaningful standard for balancing privacy interests against law enforcement needs.”³ Besides invading everyday privacy, geofence warrants may have a chilling effect on civil liberties–they may inadvertently catch people at rallies or political demonstrations, religious services, reproductive health clinics, and other events people may not want others to know they are at for personal reasons. This may lead
them to change their behavior in anticipation of surveillance, like not attending events they otherwise would have. Finally, technological issues with location accuracy may mean false convictions – such as if people are “seen” through geofencing in locations they actually weren’t in – or inaccuracies in the prosecuting process.
Policy Solutions
The Supreme Court should rule in favor of Chatrie. The geofence warrant used in his case violated the Fourth Amendment by authorizing the collection of location data from every Google user within a broad area over a one-hour period, regardless of any individualized suspicion. Investigators initially obtained anonymized
location data for dozens of devices and then narrowed the list until they identified Chatrie's device, with no probable cause linking Chatrie to the robbery. This approach resembles the general warrants the Fourth Amendment was designed to prohibit. Legislatures must prohibit law enforcement and investigators from using
geofence warrants to acquire data on everyone who was merely near a crime scene. Instead, lawmakers should require warrants to be narrowly tailored, supported by individualized probable cause, and subject to strict judicial oversight. Such reforms would allow law enforcement to continue utilizing technological tools while protecting the privacy rights and civil liberties of innocent individuals.
¹ SCOTUSblog, “Chatrie v. United States,” accessed June 22, 2026, https://www.scotusblog.com/cases/chatrie-v-united-states/.
² Joanna R. Lampe, “Geofence Warrants and the Fourth Amendment,” Congressional Research Service, Legal Sidebar LSB11274, updated January 22, 2026, accessed June 22, 2026, https://www.congress.gov/crs-product/LSB11274.
³ Jackie O’Neil, Much Ado About Geofence Warrants, Harv. L. Rev. Blog (Feb. 18, 2025), https://harvardlawreview.org/blog/2025/02/much-ado-about-geofence-warrants/.
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