Chatrie v. United States, Docket No. 25-112

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Your phone's location history is now legally protected, and police cannot access it without convincing a judge they have good reason. Even just a couple of hours worth of data. The decision protects millions of Americans who use Google's location tracking feature without realizing how precisely it records their movements. It's a significant win for privacy rights in the digital age, though questions remain about exactly how police can use location data going forward.

How Police Used Location Data to Solve a Crime

In 2021, someone robbed a credit union in Virginia while apparently talking on a cell phone. Police didn't know who did it, but they asked Google to tell them which phones were near the crime scene at the time of the robbery.

Here's how it worked. Police drew an invisible circle around the credit union and asked Google to hand over location data for any phone inside that boundary during the robbery. Google gave them anonymized information about 19 devices. Police then narrowed the list by looking at which phones stayed in the area long enough to be suspicious. Eventually, they got Google to reveal the names of three people, including Okello Chatrie. He was arrested and charged with robbery and firearms offenses.

The lower courts allowed the evidence to be used against Chatrie, even though they had doubts about whether police had followed the rules. But Chatrie appealed all the way to the Supreme Court, arguing that accessing his location data without his knowledge violated his constitutional right to privacy.

What the Supreme Court Decided

In a 6-3 decision, the Supreme Court agreed with Chatrie. Justice Elena Kagan, writing for the majority, said that accessing someone's location history is a "search" under the Fourth Amendment, which protects Americans from unreasonable searches by police.

The Court pointed to three reasons why your location data deserves protection. First, Google Location History is incredibly precise. It pinpoints your phone's location within about 65 feet and records it roughly 720 times per day. Second, it creates a permanent record that police can examine anytime, long after events happen. Third, the data reveals deeply personal information about where you go, who you see, and what you believe in.

The Court rejected the government's main argument that Chatrie had given up his privacy rights by voluntarily turning on Location History. The majority noted that Google repeatedly pushes users to enable the feature, warns that phones may not work properly without it, and never clearly explains how detailed or legally accessible the data is. In other words, turning on a feature because your phone practically demands it is not the same as knowingly giving up your rights.

Why Some Justices Wanted to Go Further

Justice Ketanji Brown Jackson agreed the police needed a warrant, but she thought the warrant itself was unconstitutional. She pointed out that the warrant allowed police to gradually expand their search, accessing more sensitive information at each step, without having to prove to a judge that each new step was justified. Police started by looking at 19 phones and only narrowed the list because Google objected, not because the warrant required it.

Justice Neil Gorsuch also sided with Chatrie but for a different reason. Rather than focusing on privacy expectations, he argued that your location data is your property, similar to your car or your wallet. Just because you store it with Google doesn't mean you've given it away, any more than handing your keys to a valet means you no longer own your car.

What the Dissenters Said

Justice Samuel Alito, joined by Justices Clarence Thomas and Amy Coney Barrett, disagreed. Alito argued the Court should not have taken the case at all, since the evidence was already allowed in under an exception for good-faith police mistakes. He also noted that Google has since changed how it stores location data, making the ruling less practically important.

On the merits, Alito contended the majority stretched an earlier privacy decision too far. He pointed out that only two hours of data were involved here, not the weeks of data in the earlier case. He worried the ruling creates a rule with no clear limits, potentially requiring warrants for online shopping histories or search logs.

Cell Phone Location Data

The Supreme Court sent the case back to the lower court to decide whether the specific warrant police used actually met constitutional requirements. This means Chatrie's case is not over. But the bigger picture is police now need a warrant before accessing any amount of location data from tech companies, no matter how brief the time period.

The decision does not resolve every question. It focuses specifically on cell phone location information, though the reasoning could extend to other location data from apps. It also leaves open the question of whether the third-party doctrine, the old legal rule that you lose privacy rights when you share information with companies, still applies to digital data. Justice Gorsuch's approach, treating data as property rather than private information, offers a different path forward that future courts might follow.