Chatrie v. United States

Summary

Justice Kagan, joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, and Jackson, held that police conducted a Fourth Amendment search by obtaining Chatrie’s Google Location History data. Neither the two-hour duration of the records nor their storage with Google eliminated his reasonable expectation of privacy. The Court vacated and remanded for consideration of the warrant’s probable cause and particularity at each stage, leaving the good-faith exception unresolved. Justice Jackson, joined by Justice Sotomayor, concurred but would also find the second and third stages unconstitutional because the warrant delegated excessive discretion to officers without adequate judicial oversight. Justice Gorsuch concurred in the judgment, reasoning that Location History constituted Chatrie’s protected effects rather than relying on reasonable expectations of privacy. Justice Alito dissented, arguing that the Court should dismiss the writ or affirm on good-faith grounds and that obtaining these voluntarily disclosed, short-term records was not a search; Justice Thomas joined Part I, and Justice Barrett joined Parts II–B, II–C–1, and II–C–2. Justice Barrett separately dissented, accepting Carpenter and the certiorari grant but concluding that Chatrie lacked a reasonable expectation of privacy in voluntarily disclosed information about his public movements.