On June 29, 2026, the Supreme Court of the United States ruled in Chatrie v. United States, a Fourth Amendment case on cell phone location data. The case stemmed from a credit union robbery in Midlothian, Virginia, in 2019. Police suspected that the robbery was conducted by an individual who used their cell phone in the vicinity of the crime, but they did not know who. To get the location history of a cell phone from Google, which was at that time the location of the credit union, police obtained a geofence warrant.

Google Location History is a service that helps you know where your phone is at a particular time using GPS, Wi-Fi, Bluetooth, cell-site information, and IP address. The geofence warrant was executed in three steps. First, Google gave police anonymous data about all of the phones that were within 150 meters of the credit union within 30 minutes before and after the robbery. Second, police narrowed down the list of phones and asked Google for more detailed location data on those phones over a two-hour window. Third, police narrowed the list a final time and obtained the names and phone numbers of the owners of the remaining phones. The data led police to Okello Chatrie, whose Location History data showed him in the area of the credit union before the robbery. Chatrie was charged with robbery and related firearms offenses in federal court.

The Court’s Holding on Reasonable Expectation of Privacy

The Supreme Court held that people have a reasonable expectation of privacy in their cell phone location data even if that data is stored by a private company like Google. So, police cannot use a geofence warrant to get a person’s Location History data from Google without a warrant supported by probable cause. The ruling builds on Carpenter v. United States, which held in 2018 that people have a reasonable expectation of privacy in their cell-site location data. The Court found that the same privacy expectation applies to Google Location History data, because the data can reveal where someone is, how long they’ve been there, and what other locations they have visited. In doing so, the Supreme Court rejected the government’s argument that people lack a privacy expectation in data held by third parties — a long-standing doctrine in Fourth Amendment jurisprudence that has otherwise allowed the government to access bank records, phone numbers, and other business records without a warrant.

The Supreme Court did not decide whether the specific geofence warrant used to obtain Chatrie’s Google Location History data was itself valid. Instead, it held that accessing this data was a search under the Fourth Amendment and remanded the case back to the lower courts to determine whether the warrant met the Fourth Amendment’s probable cause and particularity requirements. If a court finds that a geofence warrant lacks probable cause or particularity, the evidence obtained from it may be subject to a motion to suppress.

A Blow to the Third-Party Doctrine

For decades, courts have held that people do not have a reasonable expectation of privacy in information they voluntarily share with a third party, such as banks, phone companies, and other businesses. This third-party doctrine has given law enforcement access to bank records, phone numbers, and other personal information without a warrant.

In Chatrie v. United States, the Supreme Court ruled that the third-party doctrine does not apply to cell phone location data. The Court found that cell phone location data is fundamentally different from ordinary business records because of how detailed it is about a person’s location and behavior. It can reveal where a person has been, how long they were there, and what other places they visited — including their home, workplace, place of worship, medical facilities, and other private locations. Because cell phone location data is far more intrusive than typical business records, the Court held that it deserves a reasonable expectation of privacy.

The Court also found that cell phone location data is not “voluntarily shared” with third parties in any meaningful sense, since most people do not understand how much of their location data is collected or how it is used. On that basis, the Court held that the third-party doctrine does not apply to this type of data.

Why This Ruling Matters for Criminal Defense in New Jersey

Chatrie v. United States is the latest in a series of rulings limiting the government’s ability to access personal information without a warrant. In Carpenter v. United States, the Supreme Court held that cell-site location data is protected by the Fourth Amendment and that law enforcement must obtain a warrant supported by probable cause before accessing it. Chatrie builds on Carpenter by extending that same privacy protection to Google’s Location History data. In practical terms, this means law enforcement cannot access this kind of personal location data without a warrant backed by probable cause.

This decision gives criminal defense attorneys another tool to challenge how police use cell phone data in criminal cases. In particular, it means police cannot obtain Google’s Location History data without a valid warrant.

In New Jersey, police increasingly rely on geofence warrants, cell phone tracking data, and other digital evidence to investigate and prosecute a wide range of offenses, including robbery, weapons offenses, drug distribution, burglary, conspiracy, and homicide. Chatrie v. United States confirms that this kind of digital evidence can be suppressed when police obtain it without a valid warrant supported by probable cause and particularity. This is especially relevant in New Jersey, where cell phone tracking data plays a growing role in criminal investigations.

This ruling could affect a wide range of digital evidence, including Google Location History data, cell phone tracking data, and similar records. Prosecutors must be able to show that this evidence was obtained through a valid warrant supported by probable cause. When police fail to follow the proper procedure, the defense can move to suppress the evidence. A successful motion to suppress can significantly weaken the prosecution’s case in New Jersey criminal proceedings — and in some cases, it can lead to a reduction or dismissal of charges.

What To Do If Your Case Involves Cell Phone or Location Data

If you have been arrested and the prosecution’s case relies on cell phone records, geofence warrants, Google Location History data, app-based location data, or other digital evidence, you should speak with an attorney about challenging that evidence. Your attorney should review how the evidence was obtained and what steps law enforcement took to get it.

An experienced criminal defense attorney can help you understand your legal options and build a strategy in response to this evidence. If the evidence was obtained through a warrant, your lawyer can evaluate whether that warrant was supported by probable cause and sufficient particularity. If it was obtained without a warrant, your lawyer can advise you on whether a motion to challenge the probable cause or suppress the evidence is a viable option.

In some cases, suppressing digital evidence can be one of the most effective tools available in a defense strategy. If law enforcement obtained evidence without a warrant, or under an invalid one, the defense can move to exclude it. If that motion is granted, the evidence cannot be used in court — which can substantially weaken the prosecution’s case at any stage of a criminal case.

If you are facing criminal charges in New Jersey and the prosecution’s case relies on cell phone data, a geofence warrant, Google Location History data, app-based location data, or any other form of digital evidence, it’s important to speak with a lawyer. Travis Tormey and the attorneys at the Tormey Law Firm represent clients in criminal defense matters across New Jersey. We can review your case and advise you on how to challenge the prosecution’s use of digital evidence or move to suppress it. If you were charged with a crime and believe the prosecution’s case relies on cell phone data, location data, or other digital evidence, contact Travis Tormey’s office to schedule a confidential case review at (201) 556-1570.

Frequently Asked Questions About Chatrie v. United States

What did the Supreme Court decide in Chatrie v. United States?

The Court ruled that police conduct a Fourth Amendment search when they obtain a person’s Google Location History data through a geofence warrant. This means law enforcement needs a warrant supported by probable cause to access this data.

How does this ruling affect geofence warrants?

Geofence warrants must now meet the same probable cause and particularity standards as other search warrants. If a geofence warrant falls short of these standards, the evidence it produced may be suppressed.

Does this ruling apply to criminal cases in New Jersey?

Yes. New Jersey police use geofence warrants and cell phone tracking data in cases involving robbery, weapons offenses, drug distribution, burglary, and other crimes. This ruling gives defense attorneys a stronger basis to challenge that evidence.

What should I do if my case involves cell phone location data?

Speak with a criminal defense attorney who can review how the evidence was obtained. If a warrant was invalid or missing, your attorney may be able to file a motion to suppress the evidence.