Supreme Court Geofence Warrant Ruling: What It Means for Kentucky Police and Courts

The Court did not ban geofence warrants, but it made clear that police access to phone location history constitutes a Fourth Amendment search.

Jun 30, 2026

Jefferson County Courthouse in Louisville. A Supreme Court ruling on geofence warrants gives Kentucky courts, police departments, sheriffs, prosecutors, and public defenders a clearer Fourth Amendment rule governing phone location searches. Photo: Bedford, public domain, via Wikimedia Commons.

On June 29, 2026, the U.S. Supreme Court issued its decision in Chatrie v. United States, a case involving a geofence warrant served on Google after a 2019 credit union robbery in Virginia. The Court held that police conducted a Fourth Amendment search when they obtained Okello Chatrie’s Google Location History data. The Court vacated the Fourth Circuit’s ruling and sent the case back for further review of whether the warrant satisfied probable cause and particularity at each step.

The Supreme Court did not end geofence warrants. It changed the legal starting point.

That distinction matters for Kentucky police departments, sheriff’s offices, Commonwealth’s Attorneys, county attorneys, judges, public defenders, and local governments. A geofence warrant is no longer something police can treat as ordinary third-party business data. When police ask a technology company for location records that reveal where a person’s phone was, they are asking for constitutionally protected information.

The ruling changed the starting point

The case began after a robbery at the Call Federal Credit Union in Midlothian, Virginia, on May 20, 2019. Investigators did not have a suspect. They had witness information and video suggesting the robber had approached from near an adjacent church while using a cell phone.

On June 14, 2019, police applied for a geofence warrant directed to Google. The warrant sought anonymized Location History data for devices within a 150-meter radius of the credit union during a one-hour window around the robbery. After Google returned an initial list, police requested broader movement data for some devices over a two-hour period, then identifying information for three users, including Chatrie.

A federal district court found that the warrant violated the Fourth Amendment but allowed the evidence under the good-faith exception. A divided Fourth Circuit panel affirmed on a different theory, holding that no search had occurred because Chatrie had voluntarily shared the data with Google. The Supreme Court rejected the no-search theory.

Justice Elena Kagan wrote the Court’s opinion. The Court held that a person has a reasonable expectation of privacy in cell-phone location records, even when the government seeks the records from a third-party technology company and even when the time period is limited. The Court left the harder question for the Fourth Circuit: whether this particular multi-step warrant was reasonable, with enough probable cause and enough detail at each stage.

That makes this ruling important, but limited. Police may still seek location-data warrants. Courts will now have to evaluate them as searches.

A Search That Starts With a Place, Not a Suspect

A geofence warrant starts with a place and a time, then asks a company to identify devices inside that digital boundary.

A traditional search warrant usually begins with a suspect, a known device, a home, a car, or a specific account. A geofence warrant reverses that sequence. Police draw a virtual boundary around a crime scene and ask a company to search its location records for devices that were in the area.

In the Chatrie case, Google’s Location History records came from a service that recorded a user’s phone location roughly every two minutes when the feature was active. The warrant used a three-step process: first, anonymized device data within the geofence; then, movement data for the narrowed set of devices; and finally, identifying information for the users selected by the police.

The risk is built into the method. A person can be included because she lives, works, worships, waits for a bus, shops, or passes through nearby at the wrong time. The warrant can sweep in people who have no connection to the crime.

Google told the Supreme Court that geofence warrants often extend beyond the crime location. Its amicus brief said these warrants can include private homes, apartments, government buildings, hotels, places of worship, busy roads, and other locations for which law enforcement may not have particularized probable cause. Google also said it had objected to more than 3,000 overbroad geofence warrants since 2022.

There is also an operational caveat. Google has changed how it stores Location History, which affects whether mass geofence searches of Google’s own stored Location History remain available in the same way. But Google is not the only company that collects or stores location information. Other apps, data brokers, cell tower records, ride-share platforms, advertising data, and phone-related records can still create location trails that police may seek.

Kentucky already has a geofence warrant record

Kentucky is implicated because police here have used geofence warrants, Kentucky courts issue search warrants, and Kentucky now has a statewide electronic search-warrant process.

In 2021, KyCIR and Louisville Public Media reviewed local warrant records and found that LMPD officers had used geofence warrants at least 73 times since January 2020. Nearly three-fourths were tied to homicide investigations. The same reporting found that Kentucky police submitted 126 geofence warrants to Google between 2018 and 2020, though Google’s data did not identify which departments made the requests.

KyCIR found search areas that included homes, apartments, businesses, busy streets, churches, parking lots, and, in one case, a six-block radius including more than 120 homes, a bar, a gas station, a dollar store, a church, a fire department, and a major Louisville street.

Kentucky’s own law adds a second layer to this ruling. Section 10 of the Kentucky Constitution protects people from unreasonable searches and seizures and requires that warrants describe the place, person, or thing to be searched or seized as nearly as may be, be supported by probable cause, and be sworn or affirmed. KRS 455.170 allows electronic search-warrant applications only if the process meets Section 10, provides a paper copy at service, and complies with other search-warrant requirements.

Kentucky’s eSearch Warrant program is now live in all 120 counties. The Administrative Office of the Courts and Kentucky State Police collaborated on the program, and LexisNexis developed the eSearch Warrant program for KSP using the existing eWarrant platform. The Kentucky Court of Justice reported that, as of November 2025, 6,681 search-warrant applications had been filed through the program, with 4,589 executed, 73 denied, and 1,771 authorized and awaiting execution.

That statewide platform does not mean that every Kentucky warrant involves phone location data. It does mean Kentucky has a statewide place where search-warrant practice can be trained, templated, reviewed, and improved.

Louisville Shows Why Warrant Review Matters

Louisville has a documented history of search warrant problems. In 2023, the U.S. Department of Justice found reasonable cause to believe LMPD engaged in a pattern or practice of seeking search warrants in ways that violated the Fourth Amendment. DOJ said a significant number of LMPD applications lacked enough specificity and detail to establish probable cause, were overly broad in scope, and failed to establish probable cause for searching everything and everyone listed in the warrant.

That DOJ finding was not specifically about geofence warrants. It does, however, make warrant review a serious local governance issue in Louisville. When a police department already has documented problems with broad or weak warrant applications, a Supreme Court ruling on digital-location warrants belongs in local oversight conversations.

The Kentucky Department of Public Advocacy had already identified geofencing warrants as a challenge area before the Supreme Court ruled. Its May 2024 suppression manual described a geofence warrant as a search warrant that allows law enforcement to search a database for active mobile devices within a particular area, and said those warrants present an opportunity to challenge validity.

For public defenders and defense lawyers, Chatrie strengthens the argument that geofence warrants need careful review. For prosecutors, the ruling creates a practical reason to examine whether pending and future cases rely on location data obtained through broad reverse-location searches.

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Who Is Affected

The people most directly affected are criminal defendants whose cases rely on geofence evidence. If the warrant was too broad, lacked probable cause, or gave police too much discretion after the initial search, defense lawyers may challenge the evidence.

The larger affected group includes people who were near a crime scene for ordinary reasons. That includes neighbors, workers, students, customers, church members, patients, drivers, bus riders, protest attendees, witnesses, and family members.

People in high-policing neighborhoods may carry a heavier burden. If geofence warrants are used most often in homicide and violent-crime investigations, areas with more serious crime investigations may also experience more location-data searches. That can draw uninvolved people into police files without their knowledge.

Local governments are affected too. When a police department uses a broad digital warrant, the public may not see the search unless a criminal case is filed, a suppression motion is litigated, a warrant record is reviewed, or a journalist or resident requests documents. That gives local councils and fiscal courts a reason to request aggregate reporting, written policies, and training records.

Questions for Police Chiefs, Sheriffs, Courts, and Councils

The first local question is simple: which Kentucky agencies are still using reverse-location warrants, and under what written rules?

Ask city councils, fiscal courts, police chiefs, and sheriffs for the agency’s policies on geofence warrants, reverse-location warrants, cell-tower dump warrants, data-broker location searches, and app-based location data. If the agency has no policy, that answer is useful.

Request aggregate numbers: how many geofence or reverse-location warrants the agency sought each year; how many were approved or denied; what types of cases they involved; and whether the warrants included homes, schools, houses of worship, medical facilities, protests, or other sensitive locations.

Ask the Administrative Office of the Courts and the Kentucky State Police whether eSearch Warrant forms or training materials will be updated after Chatrie. You can also ask whether electronic warrant applications include prompts for area size, time period, staged access, de-anonymization, sensitive locations, and probable cause for each step.

In Louisville, ask the Metro Council and LMPD whether the department has a current geofence-warrant policy, whether officers receive specific training, whether prosecutors or legal advisors review applications before filing, and whether DOJ-related reforms cover digital location warrants.

The ruling gives Kentuckians a better accountability question to ask before a search becomes invisible inside a criminal case file.

If police want location data from everyone near a place at a particular time, who checks the boundary, the time window, the reason, the narrowing steps, and the final identification request?

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