Chatrie v. United States
Decision
BrynoDC Coverage 2 videos
Opinion of the Court
Overview
Overview
A case in which the Court will decide whether execution of a geofence warrant in this case violated the Fourth Amendment.
The Facts
Facts
After a 2019 armed bank robbery in Virginia, police obtained a geofence warrant compelling Google to disclose the location data of all devices within a 17.5-acre area during the crime. Google produced anonymized data for all nearby devices, then, without additional judicial approval, was asked to deanonymize three devices, leading to the identification and arrest of Okello Chatrie. Chatrie moved to suppress, arguing the geofence warrant was an unconstitutional general warrant.
The Issue
Issue
Whether a geofence warrant compelling a technology company to disclose the identities and location data of all electronic devices within a defined geographic area at a particular time constitutes a Fourth Amendment search, and if so, whether the warrant satisfied the Fourth Amendment's particularity requirement.
The Rules
Rule
Under Carpenter v. United States, 585 U.S. 296 (2018), the government's warrantless acquisition of comprehensive historical cell-site location data constitutes a Fourth Amendment search. The Fourth Amendment's particularity requirement commands that warrants describe with reasonable precision the place to be searched and persons or things to be seized. Geofence warrants present novel particularity questions because they sweep in the data of all individuals, including innocent persons, present in a geographic area.
The Application
Analysis
The government argues geofence warrants are constitutionally permissible investigative tools that satisfy the Fourth Amendment. The warrant specified a geographic area and timeframe tied to a specific crime, providing the judicial oversight the Constitution requires. Law enforcement needs modern digital tools to investigate crimes effectively.
The Conclusion
Conclusion
[Awaiting opinion]
Flag an issue
This tracker is maintained by BrynoDC and is free because readers fund it. Support