What the Minnesota Supreme Court's Geofence Warrant Ruling Actually Means

What a geofence warrant actually is

Most criminal cases start with a suspect and work outward. A geofence warrant works the other way. 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. From a pool of anonymized devices, the search narrows to a few, then to a name.

That is exactly how it played out here. Investigating a homicide, officers drew a roughly 65-by-290-foot box around the culvert where the victim's body was found, narrowed the request to two seven-day windows, and got back 19 devices - one of which had lingered in the area for about ten minutes. Police then sought expanded data on that device and a second warrant, which led to Ivan Contreras-Sanchez. He later confessed, and a jury convicted him of second-degree murder.

What the court actually held

The Minnesota Supreme Court reached three conclusions worth understanding clearly. First, cell phone users have a reasonable expectation of privacy in the location data Google stores about them - so when the government accesses that data, it is conducting a search under Article I, Section 10 of the Minnesota Constitution, and it needs a warrant.

Second, geofence warrants are not categorically unconstitutional. The court declined to brand them inherently general warrants, and it found that this particular warrant was actually supported by probable cause. That matters - the court did not say geofence warrants are banned, or that this one lacked a factual basis.

Third - and this is what decided the case - the warrant was not particular enough. After the geofence pulled in a broad set of anonymized device IDs, the warrant let law enforcement decide on its own which IDs to investigate further, without judicial oversight at that narrowing step. That unchecked discretion was the constitutional problem. The court reversed the conviction and sent the case back.

What the U.S. Supreme Court held in Chatrie

On June 29, 2026, the U.S. Supreme Court decided Chatrie v. United States. In an opinion by Justice Kagan, the Court held that police conduct a Fourth Amendment search when they obtain a person's Google "Location History," because a person has a reasonable expectation of privacy in that location data - even when it covers only a couple of hours, and even though a third-party company holds it. That extends the logic of Carpenter v. United States from cell-site data to the more precise location records Google keeps.

But the Court decided only that threshold question. It did not rule that geofence warrants are categorically unconstitutional, and it did not decide whether the warrant in that case was valid. Instead, it sent the case back to the lower court to decide whether the warrant met the Fourth Amendment's probable-cause and particularity requirements at each step. A footnote also noted that in July 2025 Google changed how it stores Location History - now on a user's own device rather than Google's servers - and represents that it can no longer respond to geofence warrants seeking that data going forward.

How the two rulings fit together

Contreras-Sanchez and Chatrie answer overlapping questions under two different constitutions, and they converge. Contreras-Sanchez held that accessing Google location data is a search under Article I, Section 10 of the Minnesota Constitution. Chatrie held the same thing under the Fourth Amendment. For a Minnesota defendant, that means the core argument - that the government needs a valid warrant to obtain this data - now rests on both a state and a federal foundation.

Just as important is what neither court did. Both decided that accessing the data is a search, and both then declined to decide whether the particular warrant was valid - Contreras-Sanchez resolving its case on a particularity defect under state law, Chatrie remanding the warrant question to the lower court. The broader question some expected Chatrie to settle - whether a geofence warrant is an unconstitutional general warrant - remains open. And the concerns line up: Chatrie's concurrence focused on the multi-step process letting officers narrow the device list without a magistrate's oversight, which is the same unchecked-discretion problem the Minnesota court identified. Both opinions point at the narrowing step as the place these warrants are most vulnerable to challenge.

What was unusual about how Contreras-Sanchez came down

The decision was split, and the split was about timing. The majority, authored by Justice Hennesy and joined by Justices Thissen and Procaccini, decided now. Chief Justice Hudson concurred, and Justice McKeig, joined by Justice Moore, dissented - both questioning whether the court should have waited for Chatrie before issuing an opinion at all. Justice Gaitas did not participate.

Justice McKeig gave three reasons to wait: the majority leaned heavily on federal cases without grounding the result in an independent state-law basis; the defendant had not objected to staying the case pending the U.S. Supreme Court; and the Minnesota Legislature is itself considering a statute that would limit the government's ability to obtain this kind of location data in nonemergency situations. The majority's answer was essentially that the court owed Minnesotans a decision without delay. That disagreement - decide now versus wait for federal guidance and the Legislature - is the real story of how this ruling came down.

What this means in Minnesota now

For anyone whose case involved a geofence warrant, this ruling is significant but not a magic wand. It does not invalidate every geofence warrant ever issued in Minnesota. Each warrant will be evaluated on its own language and scope - and the key question this case puts front and center is whether the warrant gave law enforcement unchecked discretion at the narrowing step, without judicial oversight.

Whether the ruling helps a specific case also depends on the usual things: the facts, what the warrant actually said, whether the issue was preserved, and - still unresolved here - whether a good-faith exception or harmless-error analysis applies on remand. So this is a real and useful tool for challenging geofence evidence, but it is a fact-specific one, not an automatic win.