The U.S. Supreme Court has agreed to hear a case that could define whether police can sweep up Google users’ location data to identify crime suspects, setting up a major Fourth Amendment test of digital-age surveillance. In Okello T. Chatrie v. United States, No. 25-112, the justices will consider whether geofence warrants, which compel Google to hand over Location History records for every device near a crime scene, violate constitutional protections against unreasonable searches. The case is on the Court’s calendar for the 2025–26 term, and the outcome could affect how law enforcement agencies across the country pursue digital evidence.
The case arrives at a moment when courts are still grappling with how to apply analog-era doctrines to pervasive digital tracking. Geofence warrants sit at the intersection of those tensions: they rely on detailed location trails generated by smartphones, yet are governed by precedents that assumed records were sparse and individually targeted. As more investigations turn on data held by large technology companies, the Court’s ruling is poised to either rein in or validate a powerful investigative technique whose use has expanded far faster than the law that constrains it.
A Virginia Bank Robbery That Reached the Supreme Court
The case traces back to a 2019 bank robbery in Midlothian, Virginia. Investigators obtained a warrant requiring Google to produce Location History data for all devices detected within a geographic boundary around the crime scene during a specific window of time. That data led authorities to Okello Chatrie, who was charged and ultimately convicted. But the legal fight over how police obtained the evidence has outlasted the criminal case itself, climbing through the federal courts for more than six years. Chatrie challenged the warrant as an unconstitutional dragnet, arguing it forced Google to turn over sensitive location records belonging to potentially hundreds of uninvolved people who happened to be nearby.
According to the Supreme Court docket, the justices granted review and limited it to the question of whether the geofence warrant in Chatrie’s case violated the Fourth Amendment. The filings listed on that docket include the petition, the government’s opposition, reply briefs, and numerous amicus submissions, underscoring the breadth of interest from civil liberties advocates, technology firms, and law enforcement groups. For all of those stakeholders, the Midlothian robbery has become a vehicle for testing how far the Constitution allows police to go when they tap into corporate databases to reconstruct people’s movements.
Circuit Courts Split Over Geofence Legality
Before the Supreme Court stepped in, the lower courts produced conflicting and often muddled answers. The Fourth Circuit heard Chatrie’s appeal and delivered what analysts describe as a fractured outcome. Chatrie requested an en banc rehearing before the full court, which, as described in a Brookings discussion of the order, issued an unsigned, one-sentence affirmance of his conviction in April 2025. That terse resolution was accompanied by multiple separate writings from individual judges, none of which commanded a majority rationale. The result left the governing standard for geofence warrants in the Fourth Circuit essentially undefined, even as Chatrie’s conviction remained intact.
The confusion was not limited to one court. The same Brookings analysis of geofence litigation notes that the Fifth Circuit separately concluded that a geofence warrant was unconstitutional, creating a direct split among federal appellate courts over whether this investigative tool can survive Fourth Amendment scrutiny. Privacy advocates interpret that divide as evidence that new technologies have outpaced existing legal frameworks, while prosecutors emphasize that users who opt in to Location History have shared their data with a third party, invoking the traditional doctrine that information voluntarily conveyed to companies receives less constitutional protection. That clash of views gave the Supreme Court a strong institutional reason to intervene and impose a uniform rule.
Reverse Warrants Expand Beyond Location Data
Geofence warrants are only one variety of a broader category that legal scholars call “reverse warrants.” Traditional warrants identify a specific suspect and then seek evidence about that person. Reverse warrants flip that sequence: investigators first define a digital parameter, such as a geographic area or a search query, and then ask a technology company to identify every user whose data fits the description. A February 2026 report by the Congressional Research Service surveys both geofence and keyword warrants and describes keyword warrants by discussing cases including United States v. Smith, in which law enforcement obtained a warrant for records of users who entered particular search terms into Google during a specified period.
The distinction between location-based and search-based reverse warrants matters because keyword demands implicate a different dimension of privacy. While a geofence warrant captures where someone physically stood, a keyword warrant captures what someone thought to look up online, potentially revealing interests, fears, or political and religious views. Critics argue that this threatens free inquiry and effectively turns search engines into government surveillance tools, especially when users are unaware that their queries might later be scrutinized. Law enforcement officials counter that such warrants still require judicial approval and can be drafted to focus on narrow, crime-linked terms, such as the address of a bombed building or a victim’s name. Yet neither Congress nor the Supreme Court has articulated a clear rule for any type of reverse warrant, leaving judges to improvise as these techniques spread.
What the Court’s Decision Could Change
The Supreme Court’s ruling in Chatrie will not directly address keyword warrants, since the case arises from geofence technology alone. But the reasoning the justices adopt is likely to ripple well beyond location data. If the Court holds that geofence warrants are categorically unconstitutional because they sweep in records from large numbers of people who are not suspected of wrongdoing, that logic could apply with similar force to keyword warrants and other reverse-order searches. On the other hand, if the Court concludes that users who enable Location History have no reasonable expectation of privacy in that data, prosecutors could gain a durable precedent for demanding bulk records from technology platforms whenever they can persuade a judge that the information might help solve a crime.
The practical stakes are personal and widespread. Anyone who carries a smartphone with location services enabled, or who uses Google Search while logged in, could have their data caught in a future reverse warrant, even if they never become a suspect. The Midlothian robbery case began with a single bank branch, but the legal principle at issue touches every device in every pocket. The Associated Press reports that Google has changed how it stores Location History in recent years, moving much of the data from centralized servers to individual phones, a shift that can limit what the company is able to provide in response to sweeping warrants. Even so, as long as law enforcement can obtain large volumes of digital records from private companies, the Court’s decision in Chatrie will shape the balance between investigative power and privacy in the networked world.
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*This article was researched with the help of AI, with human editors creating the final content.
