AI Consensus Solution

Re-decided holding: The government's acquisition of Google Location History data via a geofence warrant does not violate the Fourth Amendment because the data was voluntarily disclosed to a third party and the warrant was supported by probable cause.

Mode: Scotus Opinion Model: deepseek/deepseek-v4-flash Drafted: 2026.06.30
Supreme Court opinion

Chatrie v. United States

Elana Kagan

Author
Elana Kagan
Filed
2026-06-29
Citation
—
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“AI Consensus” · Working Draft

Re-decided holding: The government's acquisition of Google Location History data via a geofence warrant does not violate the Fourth Amendment because the data was voluntarily disclosed to a third party and the warrant was supported by probable cause.

Whether police officers conducted a Fourth Amendment search when they obtained a geofence warrant and acquired Okello Chatrie's Google Location History data without a warrant supported by probable cause particularized to him.

Constitutional concerns with the original

  1. The majority opinion relies on the 'reasonable expectation of privacy' test from Katz v. United States (1967), which is a post-1900 precedent that departs from the original meaning of the Fourth Amendment. The original meaning protects persons, houses, papers, and effects against unreasonable searches and seizures, not subjective expectations of privacy.
  2. The majority extends Carpenter v. United States (2018), another post-1900 precedent, without grounding the holding in the text or ratification-era understanding of what constitutes a 'search' under the Fourth Amendment.
  3. The opinion treats Google Location History data as analogous to 'papers' or 'effects' without addressing whether the data is voluntarily disclosed to a third party (Google), which under original meaning would not be a search because the government obtained it from the third party, not from the defendant's person or property.

Solution text

1) The question is whether the police violated the Fourth Amendment when they obtained Okello Chatrie's Google Location History data through a geofence warrant. 2) The Fourth Amendment provides: 'The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.' 3) At the time of ratification, a 'search' occurred when the government physically intruded upon a person's property or effects. The Founders understood that information voluntarily given to a third party—such as a bank or a messenger—was not protected by the Fourth Amendment because the individual assumed the risk that the third party would disclose it. The geofence warrant here sought data that Chatrie voluntarily shared with Google by enabling Location History. The warrant described with particularity the place (the geofence area) and the things to be seized (location data), and was supported by probable cause based on witness statements and surveillance footage. 4) The holding is that the geofence warrant was valid under the Fourth Amendment. The government did not conduct a search because it obtained data from a third party (Google) that Chatrie voluntarily disclosed. Even if it were a search, the warrant satisfied the Fourth Amendment's requirements: it was based on probable cause, supported by oath, and particularly described the data to be seized. 5) Downstream, this means that law enforcement may use geofence warrants to obtain location data from third-party providers, provided the warrant meets the traditional requirements of probable cause and particularity. This does not affect the exclusionary rule for warrants that lack probable cause or particularity.

Operative provisions

remedy
The judgment of the Fourth Circuit is affirmed on the ground that no Fourth Amendment search occurred because Chatrie voluntarily disclosed his Location History data to Google. The geofence warrant was valid under the Fourth Amendment.
stare decisis treatment
Carpenter v. United States (2018) is overruled to the extent it held that accessing cell-site location information from a third party constitutes a search. The third-party doctrine, as understood at ratification, applies: information voluntarily disclosed to a third party is not protected by the Fourth Amendment.
scope of holding
This holding applies only to geofence warrants seeking location data from third-party providers where the user has voluntarily enabled the service and the warrant is supported by probable cause and particularity. It does not address physical tracking devices or searches of a person's own device.

Bipartisan rationale

A textualist holding respects both Democratic concerns about privacy and Republican concerns about law enforcement. It honors Democratic priorities by requiring a warrant based on probable cause and particularity, ensuring judicial oversight. It honors Republican priorities by allowing law enforcement to use modern investigative tools consistent with original meaning, avoiding a blanket prohibition that would hamper crime-solving. Both parties can agree that the Fourth Amendment's text and original meaning provide a stable, predictable standard that balances privacy and security.

Constitutional citations

  • → Fourth Amendment
  • → Article III, Section 2 (judicial power to interpret the Constitution)
  • → Federalist No. 84 (on the necessity of the Fourth Amendment to protect against general warrants)

Vote-count path

N/A — judicial holding.

Drafted by the OpenOS AI legislature · deepseek/deepseek-v4-flash · 2026.06.30 06:01 UTC · ← Back to the Republic