Should police access to Google Location History count as a Fourth Amendment search?

The government argued that voluntary sharing removed a privacy interest in Google Location History. The Supreme Court treated police access as a search, while dissents and the warrant's legality raise separate questions.

Claim in dispute

Chatrie lacked a reasonable expectation of privacy in short-term location information he voluntarily shared with Google.

The U.S. Supreme Court Building's west facade and columns in Washington.
The U.S. Supreme Court Building in Washington, photographed on January 27, 2016.

Case period:

Published by The Dispute Index editorial teamPublished Updated

Google LLCUnited States Department of JusticeSupreme Court of the United StatesSamuel AlitoAmerican Civil Liberties UnionNetChoice

Overview

Chatrie concerns a Google geofence warrant used to identify people near a Virginia credit-union robbery in 2019. Police first obtained anonymous location data, then sought more data for a subset of devices and identifying information for three users. The constitutional dispute reached the Supreme Court after Chatrie's July 2025 petition (opens in a new tab).

The United States' March 25 merits brief (opens in a new tab) argues that voluntary disclosure of short-term public movements left no reasonable expectation of privacy. Alternatively, it argues that the warrant was reasonable. The ACLU and its partners (opens in a new tab) oppose that approach and seek broader restrictions. NetChoice (opens in a new tab) argues that users retain interests in data they entrust to service providers.

The June 29 opinion (opens in a new tab) holds that police conducted a Fourth Amendment search when they acquired Location History. Chief Justice John Roberts and Justices Sonia Sotomayor, Brett Kavanaugh and Ketanji Brown Jackson joined Elena Kagan's majority opinion. Neil Gorsuch concurred in the judgment on a property-based rationale. Alito dissented, arguing that the limited, voluntarily shared data did not receive the protection applied to prolonged location tracking. Clarence Thomas joined Part I of Alito's dissent. Amy Coney Barrett joined Parts II-B, II-C-1 and II-C-2 and filed her own dissent.

A search is not automatically an unreasonable search. The majority remanded questions about probable cause and particularity and did not order evidence suppressed or overturn Chatrie's conviction. The historical data system also matters: the Court records Google's representation that its move to on-device storage left it unable to answer Location History geofence warrants. That does not establish that police cannot seek location evidence by other means.

The fixed dispute is the government's no-search treatment of Location History, which the Supreme Court rejected. Whether the user voluntarily surrendered privacy is part of the disagreement, not an assumption of this case.

People in this case

Timeline

4 timeline entries on this page. Dates: January 16, 2026 to June 29, 2026

  1. January 2026

    1 event

    1. Supreme Court agrees to hear the search question

      The Court grants Chatrie's petition limited to the first question presented.

      [01]Supreme Court docket for Chatrie v. United States

      The docket records filing, argument and judgment dates and identifies the joins in the separate opinions.

      Supreme Court docket for Chatrie v. United StatesProceedings: July 28, 2025 through June 29, 2026.
  2. 45 days between recorded events

    March 2026

    2 events

    1. ACLU partners and NetChoice file privacy briefs

      Reaction

      The groups argue that access to Location History should receive constitutional protection, using different arguments and requested remedies.

      [02]ACLU and partner organizations' Chatrie amicus brief

      The ACLU, ACLU of Virginia, EFF and Georgetown's privacy center jointly argue for constitutional limits on geofence searches. Their request to invalidate such warrants is broader than the Court's eventual holding.

      ACLU and partner organizations' Chatrie amicus briefIntroduction and Summary of Argument, pages 1-4.
      [03]NetChoice's Chatrie amicus brief

      NetChoice supports privacy protection for users' location data and proposes property and bailment principles as an independent basis.

      NetChoice's Chatrie amicus briefSummary of Argument, pages 1-5; property-based argument, pages 5-13.
    2. Government defends location-data acquisition

      Reaction

      The United States submits its merits brief arguing no protected privacy interest and, alternatively, a reasonable warrant-based search.

      [04]United States merits brief in Chatrie

      The government argues that the data was voluntarily shared and alternatively defends the warrant's reasonableness. These are its litigation arguments.

      United States merits brief in ChatrieSummary of Argument, pages 12-14; no-search argument, pages 15-35.
  3. 96 days between recorded events

    June 2026

    1 event

    1. Supreme Court treats Location History access as a search

      Six justices support the judgment. Five join Kagan's reasoning, with Gorsuch concurring in the judgment. The Court remands reasonableness questions and does not order evidence suppressed.

      [05]Chatrie v. United States: Supreme Court opinion and separate opinions

      The judgment treats acquisition of Location History as a search and remands questions about the warrant's reasonableness. It does not invalidate every geofence warrant or order suppression of the evidence.

      Chatrie v. United States: Supreme Court opinion and separate opinionsMajority pages 2, 4, 24-33; Alito dissent pages 12-17; Gorsuch concurrence and Barrett dissent.
      [01]Supreme Court docket for Chatrie v. United States

      The docket records filing, argument and judgment dates and identifies the joins in the separate opinions.

      Supreme Court docket for Chatrie v. United StatesProceedings: July 28, 2025 through June 29, 2026.

Claims

Claims separate what was said from what is contested. Follow each source for the original wording and context.

What's disputed

Disputed claim

Chatrie lacked a reasonable expectation of privacy in short-term location information he voluntarily shared with Google.

United States Department of Justice

Sources (1)

Disputed claim

Acquiring Google location data through geofence warrants is a Fourth Amendment search even when the data covers a short period.

American Civil Liberties Union

Sources (1)

Arguments

  1. Documented position

    ACLU partners and NetChoice

    Entrusting data does not surrender all privacy

    The ACLU emphasizes the revealing reach of location searches. NetChoice argues that users retain property and privacy interests when they entrust their data to a provider.

    Limit of this argument

    Their arguments differ, and constitutional search protection does not make every warrant invalid.

    Read sources

    Sources

  1. Documented position

    United States merits brief and Alito's dissent

    A limited record voluntarily given to Google

    The government and Alito argue that short-term public movements from an optional service differ from unavoidable, prolonged cell-site records. The government separately defends the judicial warrant.

    Limit of this argument

    The majority rejected the no-search theory. Warrant reasonableness and suppression are separate questions.

    Read sources

    Sources

Response record

Responses

Latest recorded positions: 4. Dates: March 2, 2026 to June 29, 2026

Choose one response filter, or select All responses to see the full record.

4 responses on this page

  1. Samuel AlitoAssociate justice of the Supreme Court, dissentingDirectly involved
    "So, by giving Google his location information for its own use, Chatrie assumed the risk that Google might disclose location information to others, including the police."
    Defended or excused

    Case context: Should police access to Google Location History count as a Fourth Amendment search?

    Read more

    Alito argued that sharing location information for Google's own use meant assuming the risk of police disclosure.

    Before the statement

    Alito compares Location History to records covered by earlier third-party doctrine decisions.

    After the statement

    His dissent distinguishes this limited, optional service from prolonged cell-site tracking and also raises good-faith and advisory-opinion objections.

    Chatrie v. United States: Supreme Court opinion and separate opinionsMajority pages 2, 4, 24-33; Alito dissent pages 12-17; Gorsuch concurrence and Barrett dissent.

    Why this label?

    The case examines the no-search treatment of voluntarily shared Location History. Alito defends that treatment. His procedural objections do not erase his substantive position on privacy.

    This label describes the statement's response within the context above.

  2. United States Department of JusticeUnited States government, represented by the Department of JusticeDirectly involved
    "As a threshold matter, petitioner lacks a cognizable Fourth Amendment interest in the information that Google provided to law enforcement."
    Defended or excused

    Case context: Should police access to Google Location History count as a Fourth Amendment search?

    Read more

    The government argued that voluntarily shared Location History carried no protected privacy interest.

    Before the statement

    The brief describes the warrant as a limited request for location information near the robbery.

    After the statement

    It also argues that any search was reasonable because police obtained and followed a judicial warrant.

    United States merits brief in ChatrieSummary of Argument, pages 12-14; no-search argument, pages 15-35.

    Why this label?

    The case examines treating Google Location History as outside Fourth Amendment search protection. The government defends that treatment, alleging voluntary sharing and citing the limited period involved.

    This label describes the statement's response within the context above.

  3. American Civil Liberties UnionCivil-liberties organization, in a joint amicus briefDirectly involved
    "Letting that power go unchecked is inconsistent with basic freedoms in a democratic society."
    Condemned

    Case context: Should police access to Google Location History count as a Fourth Amendment search?

    Read more

    The ACLU and its partners rejected unchecked geofence access and sought constitutional restrictions.

    Before the statement

    The brief argues that police can reconstruct people's locations in ways ordinary observation could not.

    After the statement

    The signers seek a ruling against geofence warrants as general warrants, or safeguards if the Court disagrees.

    ACLU and partner organizations' Chatrie amicus briefIntroduction and Summary of Argument, pages 1-4.

    Why this label?

    The case examines exempting location-data acquisition from constitutional search protection. The joint brief criticizes unchecked access and argues that the Fourth Amendment applies. Its broader requested remedy was not the Court's final holding.

    This label describes the statement's response within the context above.

  4. NetChoiceTrade association, in a Supreme Court amicus briefDirectly involved
    "individuals do not lose their privacy interests just because the data is temporarily stored, with the user’s permission, with an online service provider."
    Condemned

    Case context: Should police access to Google Location History count as a Fourth Amendment search?

    Read more

    NetChoice argued that entrusting location data to a provider does not remove property or privacy interests.

    Before the statement

    NetChoice supports treating acquisition as a search under existing privacy doctrine.

    After the statement

    The brief proposes property and bailment principles as an independent basis for protection. The Court later held that acquisition was a search, without resolving the warrant's reasonableness.

    NetChoice's Chatrie amicus briefSummary of Argument, pages 1-5; property-based argument, pages 5-13.

    Why this label?

    The case examines the government's no-search treatment of Location History. NetChoice's brief supports the petitioner and substantively rejects that treatment, arguing that users retain constitutional interests in entrusted data. Its property argument supplies a reason for that rejection, not merely a change of terminology.

    This label describes the statement's response within the context above.

Sources

(5)

Original text

Chatrie v. United States: Supreme Court opinion and separate opinions

Chatrie v. United States: Supreme Court opinion and separate opinions (opens in a new tab)Majority pages 2, 4, 24-33; Alito dissent pages 12-17; Gorsuch concurrence and Barrett dissent.
Read source (opens in a new tab)

Relevant passage: Majority pages 2, 4, 24-33; Alito dissent pages 12-17; Gorsuch concurrence and Barrett dissent.

About this source

The judgment treats acquisition of Location History as a search and remands questions about the warrant's reasonableness. It does not invalidate every geofence warrant or order suppression of the evidence.

Author
Supreme Court of the United States
Published
Accessed

Original text

Supreme Court docket for Chatrie v. United States

Supreme Court docket for Chatrie v. United States (opens in a new tab)Proceedings: July 28, 2025 through June 29, 2026.
Read source (opens in a new tab)

Relevant passage: Proceedings: July 28, 2025 through June 29, 2026.

About this source

The docket records filing, argument and judgment dates and identifies the joins in the separate opinions.

Author
Supreme Court of the United States
Accessed
Archived copy (opens in a new tab)

Original text

NetChoice's Chatrie amicus brief

NetChoice's Chatrie amicus brief (opens in a new tab)Summary of Argument, pages 1-5; property-based argument, pages 5-13.
Read source (opens in a new tab)

Relevant passage: Summary of Argument, pages 1-5; property-based argument, pages 5-13.

About this source

NetChoice supports privacy protection for users' location data and proposes property and bailment principles as an independent basis.

Author
NetChoice
Published
Accessed
Archived copy (opens in a new tab)

Original text

ACLU and partner organizations' Chatrie amicus brief

Read source (opens in a new tab)

Relevant passage: Introduction and Summary of Argument, pages 1-4.

About this source

The ACLU, ACLU of Virginia, EFF and Georgetown's privacy center jointly argue for constitutional limits on geofence searches. Their request to invalidate such warrants is broader than the Court's eventual holding.

Author
American Civil Liberties Union and co-signing organizations
Published
Accessed
Archived copy (opens in a new tab)

Original text

United States merits brief in Chatrie

United States merits brief in Chatrie (opens in a new tab)Summary of Argument, pages 12-14; no-search argument, pages 15-35.
Read source (opens in a new tab)

Relevant passage: Summary of Argument, pages 12-14; no-search argument, pages 15-35.

About this source

The government argues that the data was voluntarily shared and alternatively defends the warrant's reasonableness. These are its litigation arguments.

Author
United States Department of Justice
Published
Accessed

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Cite this record

Publisher
The Dispute Index
Title
Should police access to Google Location History count as a Fourth Amendment search?
First published
Last updated
Permalink
https://disputeindex.com/cases/chatrie-google-location-history-fourth-amendment-privacy

The Dispute Index. "Should police access to Google Location History count as a Fourth Amendment search?". First published: 2026-10-12. Last updated: 2026-10-12. https://disputeindex.com/cases/chatrie-google-location-history-fourth-amendment-privacy