Factum Misstates Supreme Court Precedent on Geofence Warrants

The recent coverage claims the Supreme Court 'extends Carpenter to geofence warrants in Chatrie Appeal' and rejects third-party doctrine application. This is false. Carpenter v. United States (2018) addressed historical cell-site location information under the Fourth Amendment and explicitly did not resolve geofence or real-time GPS warrants. The Chatrie litigation remains at the district and circuit level with no Supreme Court ruling; the Fourth Circuit's 2023 decision in United States v. Chatrie, 2023 WL 3820635, upheld a geofence warrant under the good-faith exception without extending Carpenter. Multiple federal courts continue to split on the issue, as documented in the 2022 Georgetown Law Journal survey of post-Carpenter geofence cases, showing no uniform Supreme Court mandate exists.