Supreme Court Extends Carpenter to Geofence Warrants in Chatrie Appeal

The decision builds directly on Carpenter v. United States (2018), where the Court rejected the third-party doctrine for cell-site location information. Here the evidence trail shows a geofence warrant issued in 2019 captured location pings from multiple devices near a Virginia bank robbery without individualized suspicion. Court filings confirm the warrant returned data on at least 19 devices before narrowing to Chatrie, whose phone placed him inside the geofence radius during the robbery window. Procurement and training records from multiple agencies reveal geofence warrants increased sharply after 2018, often issued as administrative tools rather than traditional warrants. The majority opinion explicitly notes that voluntary sharing with Google does not equate to disclosure to law enforcement, creating tension with Alito's dissent that treats location history as fully relinquished. This pattern matches post-Carpenter litigation where courts have split on whether geofences constitute general warrants. The 5th Circuit's categorical ban on geofence warrants in a parallel case now gains weight, while the 4th Circuit's fractured affirmance in Chatrie is vacated. Operational impact centers on revised warrant templates and potential suppression motions already filed in ongoing investigations. Lower courts must now apply the reasonable-expectation test to stored location data with greater scrutiny. Next steps include DOJ guidance on geofence applications and possible legislative fixes to 18 U.S.C. § 2703. Agencies are already adjusting procurement for alternative location sources to avoid the new standard.