United States v. Chatrie
United States District Court for the Eastern District of Virginia
590 F. Supp. 3d 901, 2022 WL 628905 (2022)
Although Detective Hylton had successfully obtained geofence warrants in the past, Hylton consulted government attorneys before applying for a geofence warrant to identify a bank-robbery suspect because no court had ruled on the legality of such warrants. Detective Hylton then applied for and obtained a geofence warrant compelling Google to provide cell-phone location data in three steps. In step one, the warrant demanded anonymous location data for every device with a Google account within a 150-meter radius of the bank during a one-hour window in which the robbery occurred. Under step two, Hylton had to narrow the device list obtained from step one. For that narrowed list, Google had to provide additional location data points of travel occurring outside of the originally designated radius during a two-hour window in which the robbery occurred. After Hylton reviewed the step-two data, step three required Google to provide personally identifiable information (PII) (names and contact information) for the devices Hylton requested. As a result of this process, law enforcement identified Okello Chatrie (defendant) as the suspect. The United States indicted Chatrie for robbery. Chatrie moved to suppress the evidence obtained from the geofence warrant, arguing that the warrant violated the Fourth Amendment.
Rule of Law
Holding and Reasoning (Lauck, J.)
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