Cell-phone Location And The Fourth Amendment: What Chatrie v. United States Means For White Collar Defense

On June 29, 2026, the Supreme Court decided Chatrie v. United States, holding that obtaining cell-phone location data from a third-party technology company is a search under the Fourth Amendment. This is true even when the data is collected only briefly and even though a third party holds it.

Facts and Issue

Police investigating a Virginia bank robbery obtained a geofence warrant directed at Google. The warrant required Google to produce location data for all cell phones within 150 meters of the crime scene. It worked in three steps. First, Google provided anonymized data for all users within the geofence. Second, it provided expanded anonymized data for a smaller subset. Third, it provided identifying information for a further-narrowed group. Okello Chatrie was one of three users ultimately identified, and he was eventually charged after further investigative work. His location data placed him near the bank shortly before the robbery.

The Majority Holding

Writing for the Court, Justice Kagan held that accessing Google's Location History is a search under the Fourth Amendment. People have a reasonable expectation of privacy in their cell-phone location information. Police violate that expectation when they obtain it, even through a third-party tech company. The Court emphasized how revealing Location History is: it can pinpoint a phone within about twenty meters, records location every two minutes, and can even estimate elevation to show which floor of a building a user is on.

The Court also rejected the third-party doctrine, holding that “a cell-phone user is not to be viewed as sharing private information with third parties—which then can be freely passed on to the government—just by doing the ordinary things cell-phone users do.” Finally, the Court held that the length of the data collection does not matter. The Fourth Amendment applies “regardless of ‘the quality or quantity of information’ the government obtains.”

Implications for Fraud and White Collar Defense

Although Chatrie involved a robbery, its reasoning applies to privacy and evidence issues in white collar cases as well. In his dissent, Justice Alito raised a question the majority did not answer: do police now need a warrant to obtain Amazon purchase histories, Google search histories, or Venmo transaction logs? These types of data can paint a detailed picture of a person’s private life, and investigators routinely seek them in fraud and money laundering cases. The holding is formally limited to cell-phone location data. However, the majority’s reasoning offers a strong basis for challenging government demands for app-generated financial records and digital payment histories in future cases. Its core principle, that data created through ordinary cell-phone use carries Fourth Amendment protection, could reach well beyond location information.

Actionable Takeaways for Suppression Motions

This case gives practitioners a powerful new tool to challenge search warrants for electronic data created through routine cell-phone use. The most obvious use is to challenge warrants for location data. But as Justice Alito noted in his dissent, the reasoning may also apply whenever electronic data can reveal details of a defendant’s private life.