NACo Legal Advocacy: Chatrie v. United States

County Nexus

This case could have significant implications for counties in the realm of county data use and collection. A broad ruling could create numerous burdens and difficulties for counties and their operations.

Background

On January 16, 2026, the Supreme Court agreed to hear Chatrie v. United States which asks the court if and when the collection of data through geofencing constitutes a violation of search and seizure under the Fourth Amendment. It specifically focuses on whether the execution of a geofence warrant, issued by a judge and directing a third-party provider to disclose location history data for devices present near the scene of a crime during a limited time window, constitutes an unreasonable search.
In 2019, an armed robbery occurred at a credit union in Virginia. Law enforcement did not have an identified suspect but did have a known location and timeframe for the offense. Investigators sought and obtained a warrant from a Virginia state court authorizing a geofence request to Google. Law enforcement sought identifying information for a small number of devices in the area during that time, one of which was linked to the defendant, Okello Chatrie.
Chatrie was indicted in federal court and moved to suppress the geofence evidence arguing that the warrant violated the Fourth Amendment. The U.S. District Court for the Eastern District of Virginia agreed that the warrant raised constitutional concerns. However, the district court declined to suppress the evidence via a Constitutional exception. Chatrie appealed. A panel of the U.S. Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit granted rehearing with the full court and issued and unanimously ruled with the panel. The Supreme Court agreed to hear the case in January.  The Court must now determine when a Fourth Amendment “search” occurs in the context of modern, data driven investigations and decide whether warrants structured around place and time rather than a known suspect satisfy the Fourth Amendment’s requirements of reasonableness, probable cause, and particularity.

NACo Advocacy

NACo believes a broad ruling that treats the act of collecting or aggregating data as a search could introduce new legal uncertainty not just regarding the law enforcement tool of geofencing, but potentially across county departments that could increase compliance costs, and limit the ability to use data driven tools for legitimate public purposes. 

Counties support effective public safety tools and clear legal standards that counties can implement across services. While counties do not endorse specific technologies, counties rely on data driven systems and third-party vendors across law enforcement and non-law enforcement functions, and that unclear or overly broad legal rules can drive up costs and get overcomplicated. Therefore, the National Association of Counties and the Local Government Legal Center will weigh in as amicus in Chatrie v. United States.

Current Status

Oral arguments on this case are scheduled for April 27th and a ruling is expected at the end of the current Supreme Court term.