Case: Okello T. Chatrie v. United States, No. 25-112
Lower Court: Fourth Circuit
Docketed: 2025-07-30
Status: Granted
Question Presented: 1. Whether the execution of the geofence warrant violated the Fourth Amendment. 2. Whether the exclusionary rule should apply to the evidence derived from the geofence warrant.
On April 1, 2026, a coalition of Iowa, Michigan, and 29 other states filed an amicus brief, joining Professor Orin S. Kerr and the Local Government Legal Center in weighing in on the geofence warrant used to identify Okello Chatrie. The breadth of amicus participation — 33 briefs total — reflects how much law enforcement at every level of government has invested in the legal viability of this investigative technique.
Chatrie was convicted of armed bank robbery after investigators used a geofence warrant to compel Google to disclose location data from all devices present near the robbery site during a defined time window. The Fourth Circuit, sitting en banc, upheld the warrant, though the court was divided on the third-party doctrine's application to Google's Sensorvault database. The case was docketed at the Supreme Court in July 2025 and granted review shortly thereafter. The SCOTUSBlog case page tracks the full briefing history.
The two questions presented are analytically distinct. The first asks whether the execution of the geofence warrant violated the Fourth Amendment. The second asks whether the exclusionary rule should apply to the evidence derived from the warrant. The Court could resolve the case entirely on the second question, leaving the constitutional issue for another day.
The case arrives as courts and legislatures have struggled to apply Carpenter v. United States's reasoning beyond cell-site location records. A ruling here will clarify whether the third-party doctrine retains meaningful force when law enforcement sweeps location data from potentially thousands of uninvolved individuals to identify a single suspect.