Chatrie v. United States

In 2019, a man robbed a Virginia bank. Eyewitnesses reported seeing the robber talking on a cell phone as he approached the bank from a particular direction. To identify the suspect, police obtained an uncommon three-step geofence warrant seeking location-history data from Google. In the first step, Google produced anonymized location-history data for all devices that had been near the bank during a one-hour period centered on the robbery. Police analyzed that data to narrow the potential suspect pool. In the second step, Google provided additional anonymized location-history data for that smaller pool of devices, showing their movements over a larger geographic area during a two-hour period. Using that information, police identified three devices of interest. In the third step, Google disclosed those three users’ identities. One user was Okello Chatrie (defendant). Police used this data to continue the investigation, ultimately charging Chatrie with bank robbery in federal district court. Chatrie moved to suppress the location-history evidence, arguing that the government’s acquisition of his movements from Google was an unreasonable search under the Fourth Amendment. The district court agreed that obtaining the location-history data constituted an unreasonable search but declined to suppress the evidence because the officers had relied on the warrant in good faith. The United States Court of Appeals for the Fourth Circuit likewise admitted the evidence, but on the ground that obtaining a user’s location-history data from Google was not a Fourth Amendment search. The United States Supreme Court granted certiorari.