The Supreme Court Just Ruled on Geofence Warrants. Here's What Chatrie Actually Means for Minnesota.

First, what a geofence warrant is

Most investigations start with a suspect and work outward. A geofence warrant runs in the opposite direction. Police draw a digital box around a location and a window of time, then ask a company like Google for a list of every device that was inside that box during that window. The list starts anonymized, then narrows - from many devices, to a few, to a name. It is a way of asking, in effect, who was here when this happened?

The case the Supreme Court just decided started with a 2019 bank robbery in Virginia. Police could not identify the robber, so they got a geofence warrant directing Google to turn over location data for phones near the credit union around the time of the crime. Through a three-step narrowing process, Google eventually handed over three names. One of them was Okello Chatrie.

What the Supreme Court held

The Court answered one question clearly: obtaining a person's Google location data is a search under the Fourth Amendment. Writing for the Court, Justice Kagan reasoned that a person has a reasonable expectation of privacy in the detailed record of their movements that Google keeps - a record precise enough to place a phone within about twenty meters, logged every couple of minutes, and accurate enough to reveal which floor of a building someone is on.

That is true, the Court held, even when the data covers only a couple of hours, and even though a third-party company holds it. The decision extends Carpenter v. United States, the 2018 case that said the same thing about a less precise form of cell-phone location data. The Court's point was that Google's location history is, if anything, more revealing than what Carpenter covered, so the same privacy protection applies.

What the Court did not decide - and why that matters

Here is what surprised people who expected Chatrie to settle everything: the Court decided only the threshold question. It held that accessing the data is a search. It did not hold that geofence warrants are categorically unconstitutional. And it did not decide whether the warrant in that case was actually valid.

Instead, the Court sent the case back to the lower court to work through whether the warrant satisfied the Fourth Amendment's two core requirements - probable cause and particularity - at each step of the narrowing process. So the big categorical question some hoped Chatrie would answer - whether a geofence warrant is just an unconstitutional fishing expedition - is still open.

One more detail matters: the Court noted that in July 2025, Google changed how it stores this location data, keeping it on a user's own device rather than on Google's servers, and that Google now says it can no longer respond to these geofence warrants at all. So the specific technique at issue may be fading on its own.

How this fits with Minnesota's Contreras-Sanchez ruling

Minnesota did not wait for Chatrie. In April 2026, the Minnesota Supreme Court decided State v. Contreras-Sanchez, a homicide case built on a geofence warrant. The two rulings now sit side by side, and they line up.

Contreras-Sanchez held that accessing Google location data is a search under the Minnesota Constitution, Article I, Section 10. Chatrie held that it is a search under the Fourth Amendment of the U.S. Constitution. Same conclusion, two different constitutions. For someone facing charges in Minnesota, that matters: the argument that the government needed a valid warrant to get this data now stands on both state and federal ground.

And both courts stopped at the same place. Each decided that accessing the data is a search, and each then declined to rule the warrant itself valid or invalid. Contreras-Sanchez resolved its case on a narrower problem: the warrant let police decide, on their own, which anonymized devices to investigate further, without a judge's oversight at that narrowing step. The Minnesota court called that unchecked discretion the constitutional defect and reversed the conviction.

That is the same concern a concurring Justice flagged in Chatrie: that the multi-step process let officers expand the search at steps two and three without going back to a magistrate. In other words, both the Minnesota Supreme Court and members of the U.S. Supreme Court are pointing at the same weak spot: the moment police narrow the list of devices is where these warrants are most open to challenge.

What this means if your case involved a geofence warrant

A few honest points, because this area is easy to over-read in either direction. This is not an automatic win. Neither Chatrie nor Contreras-Sanchez banned geofence warrants or threw out every case that used one. Both rulings make clear that whether a particular warrant holds up is a fact-specific question. It depends on what the warrant actually said, whether it gave police unchecked discretion at the narrowing step, whether there was probable cause, and whether the issue was properly preserved in the case.

But it is a real and growing tool. Two courts - one applying the Minnesota Constitution, one applying the Fourth Amendment - have now confirmed that this kind of location access is a search that requires a proper warrant. That gives the defense a concrete, well-supported basis to challenge how the data was obtained and whether the warrant was particular enough.

If location data from a phone played a role in identifying you or building the case against you, it is worth having someone look closely at exactly how that data was obtained. The defect that mattered in Contreras-Sanchez, and the one a Justice highlighted in Chatrie, was not exotic. It was the everyday structure of how these warrants are written.

This is general information about a developing area of law, not legal advice. Geofence and location-data issues turn entirely on the specific facts and the specific warrant in your case. If you have questions about how location evidence is being used against you, call Keil Defense at (651) 315-3097 for a conversation about your situation.