Oral Argument Preview: Chatrie v. United States

On April 27, 2026, the U.S. Supreme Court will hear Chatrie v. United States, a case that represents a fundamental clash between the Fourth Amendment and emerging technological investigative techniques. The Court will assess the constitutionality of geofence warrants, which allow law enforcement to obtain location data stored by a service provider such as Google or Apple within the bounds, or “fence,” of a specific time and area in order to identify a potential suspect. The case may present two principal questions: First, whether the geofence warrant issued to Google constituted a Fourth Amendment “search,” and second, if so, whether it was a permissible form of a search.

The Case

Chatrie v. United States

Geofence warrants compel service providers to search through location data for cell phones and other mobile devices that were within a defined geographic area during a specified period of time, and produce information regarding the device. Their use has increased substantially over the last decade. In 2020 alone, law enforcement served 11,500 geofence warrants on Google. Chatrie arose from a $195,000 bank robbery at a Federal Credit Union in Virginia on May 20, 2019. Witnesses and security footage indicated that the robber carried both a gun and a cell phone. After pursuing several unsuccessful leads, Detective Joshua Hylton, from the Chesterfield County Police Department, obtained a search warrant from a Virginia circuit court directed to Google.

The search warrant targeted user data held by Google as part of its “Location History” service.  Location History is an optional account setting offered by Google to users through which users upload data location points to their Location History accounts. Users can then view their historical locations using the Timeline feature in Maps.  Users have control over the contents of their Location History accounts, including the ability to edit and delete the entries, and pause or unsubscribe from the service. To enable the upload of location data, a user must take a number of steps, including, turning on location sharing on the mobile devices that are to report location data, and opting in to the Location History setting on their Google account. Once enabled, Google stores the device location in the user’s Location History account, which are used for purposes such as a virtual journal of travels, personalized recommendations, and real-time traffic updates. Google also uses this data for commercial purposes, primarily for advertising. Although the number of Location History adopters is a matter of some factual dispute, there were at least “numerous tens of millions” in 2019.

To respond to geofence warrants, Google developed a three-step procedure. At Step One, law enforcement seeks an anonymized list of devices that appeared within a defined geographic area during a specified time period. To produce that list, Google searches its entire Location History database for responsive accounts. At Step Two, law enforcement reviews the information and may request additional location information for selected anonymized accounts over a broader time frame. At Step Three, law enforcement may request identifying information for accounts it considers relevant to the investigation.

In Chatrie, the geofence warrant covered a 150-meter radius surrounding the bank—encompassing public streets, private residences, and a nearby church—and sought information for all devices within the area from 30 minutes before to 30 minutes after the bank robbery. Google provided 209 location points from 19 accounts during that period. At Step Two, Hylton requested additional information on the movements of nine accounts an hour before and after the robbery, and Google provided 608 data points. At Step Three, Hylton requested identifying information for three accounts, one of which belonged to Okello T. Chatrie.

On Sept. 17, 2019, a federal grand jury in the Eastern District of Virginia indicted Chatrie with two felonies for the bank robbery. Chatrie moved to suppress the evidence obtained from the geofence warrant, arguing that it violated the Fourth Amendment. The district court held that the warrant “plainly violates the rights enshrined in the [Fourth] Amendment.” The district court nonetheless denied the motion under the good-faith exception, which excuses the Fourth Amendment’s remedy of evidentiary suppression if law enforcement acted in objectively reasonable reliance on a warrant while conducting the search, even if the warrant is later held to be unconstitutional.

On July 9, 2024, a panel of the U.S. Court of Appeals for the Fourth Circuit affirmed the district court’s denial in a 2 to 1 vote. The panel concluded that the government did not conduct a Fourth Amendment search because Chatrie lacked a reasonable expectation of privacy in two hours of location data voluntarily exposed to Google. It relied on the Supreme Court’s rulings in Smith v. Maryland and United States v. Miller, which both stand for the proposition that a person generally has no Fourth Amendment protection in information conveyed voluntarily to a third party (the “third-party doctrine”). Applying that principle, the Fourth Circuit reasoned that users who knowingly and voluntarily enable Google’s optional Location History feature assume the risk that Google may disclose their information to the government.

The panel also distinguished Chatrie from the Supreme Court’s ruling in Carpenter v. United States, in which the Supreme Court held that law enforcement had conducted a search by obtaining an extended period of cell site location information (“CSLI”). According to the Fourth Circuit panel, the two hours of anonymous data collected in Chatrie were narrower in scope than the CSLI in Carpenter. The panel also emphasized that Google’s Location History depends on a user’s affirmative consent rooted in Google’s notice of monitoring, whereas CSLI is collected more passively through ordinary cell phone use. Additionally, the Fourth Circuit found that enabling Location History is not as integral to modern life as carrying a cell phone and making phone calls generally.

In his dissent, Judge James Wynn argued that the majority’s opinion would give the government “a virtually unrestricted right” to obtain the location data of every citizen. He pointed to the Supreme Court’s concern in cases such as Riley v. California that technological advancements can expand government access to private information. Wynn posited that Google’s Location History may be even more revealing than CSLI because it can be more precise and more frequently collected. He also questioned whether users’ consent was meaningfully voluntary, given the ubiquity of digital services and the limited significance of an opt-in prompt.

The Fourth Circuit later reheard Chatrie en banc (all sitting judges were present). By granting the rehearing, the court vacated the panel decision, and in a one-page per curiam opinion after hearing arguments, it affirmed the district court’s judgment denying suppression. The en banc Fourth Circuit court was very divided in its reasoning, producing nine separate opinions.  On the issue of whether there was a search at all, the judges split seven to seven. Seven judges concluded that no Fourth Amendment search occurred due to the defendant’s third-party disclosure, and seven concluded that a search had occurred. Chief Judge Albert Diaz affirmed the district court’s ruling for the per curiam opinion, solely on the ground that the good-faith exception applied. Only Judge Roger Gregory dissented on the outcome and would have suppressed the evidence. Okello Chatrie appealed the ruling, and the Supreme Court granted certiorari on the question of whether the execution of a geofence warrant violated the Fourth Amendment. Notably, the Fifth Circuit previously confronted the constitutionality of geofence warrants, concluding in United States v. Smith that such warrants were both a search and impermissible general warrants.

The Briefs

The Petitioner, Okello Chatrie’s Brief

Chatrie’s brief advances several arguments for why the geofence warrant violated the Fourth Amendment. First, he argues that accessing Location History was a “search” under the Fourth Amendment because users have a property interest in the data and a reasonable expectation of privacy in it. Second, he contends that the geofence warrant operated as an unconstitutional general warrant and writ of assistance based on its breadth. Third, he claims that even if the warrant was not a general warrant, the Step One component of the search was unconstitutional. And fourth, he argues that Steps Two and Three of the geofence warrant were unconstitutional.

Chatrie first contends that the geofence warrant constituted a search because law enforcement both intruded on a protected property interest and invaded an area in which he had a reasonable expectation of privacy. His property-based argument relies on the Supreme Court’s holding in United States v. Jones, which held that a Fourth Amendment search occurs when the government trespasses on a constitutionally protected property interest to obtain information. Chatrie argues that users have a property interest in Location History because they can review, edit, or delete the data, reflecting a right to control and exclude others from it. He also points to other legal sources, including court decisions, state legislation, and the Stored Communications Act, as recognizing some form of user property interest in private digital data. In addition, he argues that the Fourth Amendment’s reference to “papers” and “effects” was historically understood as broad enough to encompass modern digital information. He further analogizes Google to a bailee over users’ data: Just as a sealed envelope remains protected when entrusted to the post office, digital data should remain protected when stored with a service provider.

Alternatively, Chatrie argues that Location History is protected under the Fourth Amendment through the reasonable expectation of privacy framework derived from Katz v. United States. Under Katz, the Fourth Amendment protects information where a person has both a subjective and objectively reasonable expectation of privacy in it. Chatrie compares Location History to the CSLI held to have Fourth Amendment protection in Carpenter, arguing that Location History is similarly detailed, retrospective, and revealing, and in some respects even more precise. He emphasizes that Location History can pinpoint a user’s location within roughly three meters, collect location points every two minutes, reveal elevation within a building, and retain that information indefinitely unless the user deletes it. He also argues that geofence warrants can expose visits to highly sensitive locations such as an abortion clinic or church. 

Chatrie further contends that the third-party doctrine should not govern for three reasons. First, he argues that Location History is not the kind of ordinary business record like the bank records in Miller and dialed phone numbers in Smith, but rather user-controlled private data. Second, he argues that even if it is treated as data disclosed to a third party, Carpenter’s reasoning still prevents the third-party doctrine from applying because of the volume, precision, and sensitivity of the information involved. Third, in his view, disclosure of location data is not meaningfully voluntary. He discusses how Google prompted users multiple times to enable Location History and suggested it was necessary to fully use certain services. Chatrie argues that this does not amount to genuine consent to government access. He compares Location History to the CSLI in Carpenter: While users could avoid CSLI tracking from declining to place calls, users of Location History had to navigate to a separate web interface to delete Location History data.

Chatrie next argues that if the geofence warrant is characterized as a search, the warrant itself was an unconstitutional general warrant. Warrants must be supported by probable cause and must describe a particular place to be searched and specific items to be seized. Chatrie argues that the relevant search occurred when Google reviewed every user’s Location History in its database to identify responsive users. On that view, the government effectively caused a search across a vast amount of accounts without individualized probable cause. He maintains that Google acted as an agent of the government when carrying out the search pursuant to a compulsory warrant. He again relies on Jones to argue that the government trespassed on numerous individuals’ property interests, and he contends that even if  individual accounts are not treated as property, the government still invaded each user’s reasonable expectation of privacy.

To counter the government’s argument that no search occurs until Google discovers responsive information, he invokes Arizona v. Hicks. There, the Court stated a “search is a search, even if it happens to disclose nothing but the bottom of a turntable.” Chatrie asserts that this displays that the constitutional problem does not depend on whether the search ultimately yielded responsive information. From his perspective, the government’s position is untenable because the search occurs when the accounts are examined in the first place.

Additionally, he posits that the place to be searched, listed as “Google LLC,” was insufficiently particular because the warrant did not identify a particular account and establish probable cause that evidence would be found in that account. He points to the potential consequences of a contrary rule: the government could search every user’s email account merely by referencing Google as the place to be searched. On that premise, Chatrie argues that the warrant lacked both probable cause and particularity and therefore was a general warrant because it did not identify specific accounts supported by individualized suspicion. Chatrie likens this to a search of an apartment building rather than a particular unit, or the search of all packages in a warehouse, just because there is probable cause to believe one of them contains contraband.

Chatrie argues alternatively that even if the warrant was not an unconstitutional general warrant, the Step One search was unconstitutional. He contends that the search of 19 users at Step One unnecessarily invaded privacy interests. In his view, the anonymity of each user does not eliminate the constitutional concern, particularly because the movement patterns themselves may reveal identity. He analogizes the search to law enforcement rifling through drawers without knowing in advance who owns them. Moreover, he asserts that the warrant lacked particularity because it authorized review of multiple accounts for which law enforcement lacked probable cause. More specifically, he contends there was no probable cause to search the accounts of every person who happened to be within the geofence. He further argues that United States v. Grubbs, which upheld anticipatory warrants only where there is probable cause that a triggering condition will occur, foreclosed any argument that this warrant’s open-ended narrowing process lacking probable cause for the 19 users was constitutionally permissible.

Finally, Chatrie argues that Steps Two and Three of the geofence warrant violated the Fourth Amendment. Similarly to the argument regarding Step One, Chatrie contends that the expanded disclosure of information regarding the nine accounts at Step Two and identifying disclosure of three accounts at Step Three each involved additional searches that required independent constitutional justification. From his perspective, the government should not be permitted to narrow and deepen its search of accounts without further judicial authorization. Specifically, he states that the government could have attempted to obtain a supplemental warrant but chose not to, effectively transforming Google into the judicial officer. As such, he argues that the initial warrant did not establish probable cause or particularity as to those later selected accounts.

The Respondent, The United States’ Brief

The government’s brief makes two main arguments against the petitioner. First, that Chatrie had no Fourth Amendment interest in short-term information about his cellphone’s movements that he allowed Google LLC to collect, store, and use. Second, that any search that occurred was reasonable because the government obtained a particularized warrant supported by probable cause. For these reasons, the United States argues that the decision should be affirmed.

The first main argument is that Chatrie did not have a reasonable expectation of privacy in short-term location data that he voluntarily disclosed. The government argues that petitioner had no reasonable expectation of privacy because he opted into Google’s Location History feature and because the data involved public movements. The government argues that the Supreme Court’s precedents do not support such an expectation of privacy, citing cases including Smith v. Maryland, Lopez v. United States, and United States v. Miller, that use the third-party doctrine. Respondent differentiates this case from Carpenter v. United States because the data collected in Chatrie was short-term as opposed to long-term information.

The government then argues that Google’s disclosures in response to the warrant did not violate any reasonable expectation of privacy. The data that Google disclosed only concerned Chatrie’s short-term, public movements, and this data was voluntarily given to Google. At Step One, Google gave anonymized data of the location of Chatrie’s cellphone within 150 meters of the credit union within half an hour of the robbery. The government claims that this is not private data because his presence near the scene was visible to other people. The government also argues that Chatrie did not have a reasonable expectation of privacy in the two hours of location data collected in Steps Two and Three. Although the data was deanonymized at Step Three, the government argues that it fell within the parameters of the United States v. Knotts decision, which held that a person has no reasonable expectation of privacy if the information could have been gathered by visual surveillance from public places. The government emphasizes that the short-term nature of the data collected means that there is a much lower likelihood of spotting repeated patterns that reveal privacies. Any privacy concerns were further mitigated by Chatrie’s consent to share his location data with Google during the time of the robbery.

The government argues that Chatrie’s contrary arguments are unsound. The Location History data collected differs from the CSLI collected in Carpenter because Location History is far from indispensable; activating Location History requires an affirmative act, and turning off Location History is not burdensome. The government argues that petitioner’s attempts to analogize the information collected in this case to the information collected in Carpenter are misplaced. Chatrie’s Location History was not private in that anyone could have observed him in person in public. The government is not convinced that Chatrie’s opt in to Google’s collection of Location History was not truly voluntary, because Google adequately discloses to users how they collect location data, and only one-third of users have opted in. The government argues that more information about Google’s privacy policies is readily available to users and that there is no coercion to have users opt in. The government cites Smith v. Maryland in arguing that the most important factor is whether information is voluntarily conveyed as opposed to whether the information held by the third party is confidential.

The government also argues that Chatrie’s unpreserved and unexamined property-based theory lacks foundation, asserting that the Supreme Court should not be the first to address Chatrie’s property theory as a novel argument that lacks merit. The government emphasizes that Fourth Amendment rights are not identical to property rights and the Fourth Amendment does not protect interests in all kinds of property. Any contract rights that might come about as a result of entering into agreements with Google also do not necessarily create property rights. The government argues the Supreme Court should not prematurely constitutionalize the policy debate of whether or not one’s personal data should be considered property. Furthermore, the government argues that Chatrie was not successfully able to show that Location History was his property as opposed to Google’s property—the latter of which “created, used, and controlled” the Location History records. The government analogizes it to when a tailor makes notes of someone’s measurements for his files; the note still belongs to the tailor, not to the person who was measured. Finally, the government argues that even if Chatrie had property rights to Location History information, no trespass occurred that would implicate the Fourth Amendment. In this case, Google relinquished the data because it had a good-faith belief that disclosure was reasonably necessary to comply with any legal process or governmental request.

The government’s second main argument posits that any search that occurred was reasonable because the government obtained a particularized warrant supported by probable cause. The warrant clause permits the issuance of search warrants that seek evidence held by a third party that is potentially helpful to law enforcement in the investigation of a crime, even if there are no specific subjects, as the Supreme Court held in Zurcher v. Stanford Daily. The warrant sought in this case by Hylton provided a fair probability that Google would have location information about people who were within 150 meters of the credit union around the time that it was robbed. This probability is due to the fact that most Americans own cell phones, Google could collect and store information from smartphones that had Location History enabled, and the robber was on a cell phone when he walked into the credit union. The warrant described the place to be searched and the material sought in three detailed steps. The government argues that the warrant was valid at all three stages of the search.

Even if the Court finds that Chatrie’s Fourth Amendment rights were violated, the government argues that the appropriate decision is to affirm rather than to reverse because suppression is unwarranted under the good-faith exception to the exclusionary rule.

Amicus Briefs

29 amicus briefs were filed from a variety of legal and technical professionals, companies, trade associations and nonprofit organizations. The briefs varied from case-specific factual submissions to broader arguments about the constitutional and practical consequences of geofence warrants. As a whole, the briefs generally fall into three categories: those arguing against or defending geofence warrants; those proposing competing doctrinal frameworks for analyzing digital searches under the Fourth Amendment; and those warning of the broader civil rights and policy consequences that may follow from the Court’s resolution of this case.

Constitutional Concerns Against Constitutional Support for Geofence Warrants

Several technology companies filed amicus briefs in Chatrie, many of which raised related concerns about privacy, digital storage, and the scope of geofence warrants. Google’s amicus brief sets out a detailed description of the Location History service, explaining that through it users create a private detailed journal of their location and daily life. Google describes its experience responding to geofence warrants and states that it had objected to thousands of requests as overly broad. Google also explains that, as of July 2025, all Location History data that was previously stored on Google’s servers was deleted or migrated to on-device storage, thereby eliminating its ability to respond to future geofence requests. Google argues that geofence warrants should be treated as searches and that the third-party doctrine should not apply simply because users disclose limited information to a service provider. It also points to examples of geofence warrants that reached sensitive places, such as funeral services.

Microsoft submitted an amicus brief following a similar theme—that users maintain an expectation of privacy in data stored on the cloud. It further argues that the government should be required to establish probable cause as to each individual whose data falls within the parameters of a geofence warrant, and that additional warrants should be required as the government narrows its focus in later steps.

Similarly, a group of technologists filed a brief arguing that, as a technical matter, the geofence warrant required Google to perform an account by account search in non-public Location History user accounts, not a search of a single server set or flat database. It explains that accounts are the basic abstraction cloud systems use to segregate user data and enforce access controls, so a compelled search necessarily crosses the access boundary of each account examined. The brief uses analogies like hotel rooms and safe deposit boxes to show how distinct private spaces can exist within shared infrastructure and why provider access does not convert user content into provider business records. Framing the case around compelled entry into accounts, it argues, provides a clearer and more administrable path and reduces reliance on debates about voluntariness or Carpenter style line drawing over data sensitivity or precision.

Almost all of the other amicus briefs filed in support of the petitioner argue that geofence warrants should be considered a search in the context of the Fourth Amendment. Furthermore, the majority of briefs argue that these warrants do not meet Fourth Amendment requirements when it comes to particularity and/or probable cause. Lack of particularity arguments emphasize that geofence warrants include all the data for all persons nearby. Some briefs, including one filed by American Civil Liberties Union (ACLU) and others, emphasize that in Steps Two and Three of the warrant, the scope of the data collected was widened in time and location without sufficient particularity. The ACLU and the Liberty Justice Center also argue that mere proximity to a crime or use of devices that record location data are insufficient to establish probable cause for a government search of personal data.

Many briefs in support of the petitioner also argue against the application of the third-party doctrine in this case. The brief filed by the Americans for Prosperity Foundation argues that one’s digital information does not cease to be constitutionally protected based on where it is located or stored. The brief filed by the Project for Privacy and Surveillance Accountability, Inc. argues that geofence warrants are modern general warrants enabling mass, suspicionless retrospective tracking of everyone in a fenced area, and pose acute First Amendment risks to religious freedom and association.. The brief filed by Law & Technology and Fourth Amendment scholars further argues that permission screens presented during app setup are a poor way to measure consumer privacy preferences due to the complexity and obscurity of privacy policies and the forced nature of consumer consent.

On the other side of the debate, Iowa, Michigan, 29 other states, and the District of Columbia filed an amicus brief supporting the government. They argue that geofence warrants should not be treated as categorically unconstitutional and that the relevant Fourth Amendment inquiry should instead focus on traditional warrant requirements of probable cause, particularity, and reasonableness. The states and D.C. posit that a warrant becomes “general” when it grants law enforcement excessive discretion, not merely because it implicates multiple unknown individuals. From that premise, they contend geofence warrants can operate as a properly constrained process for identifying suspects. Orin Kerr, filed an amicus brief arguing for a framework centered on whether the government invaded a “virtual locker” to govern whether law enforcement searched Chatrie’s “papers” under the Fourth Amendment.

Proposed Frameworks for Addressing Geofence Warrants

On various grounds, all the briefs filed in favor of the petitioner, and most filed in favor of neither party, argue that geofence warrants should be considered searches under the Fourth Amendment. Two of the three briefs in favor of the government don’t contest that proposition either, addressing only whether the warrant is invalid.

The Institute for Justice’s brief argues that the word “search” has been gradually collapsed by the Court and argues for a return to the ordinary meaning as “an act aimed at obtaining information.” A brief filed by the Cato Institute also argues for a return to the original meaning of “search,” and further argues that Chatrie had a property interest in his Location History records. Similarly, the brief filed by the Americans for Prosperity Foundation argues that digital information is included in the definition of personal property. Many briefs argue that geofence warrants are general warrants.

The Software & Information Industry Association also filed an amicus brief arguing that the government must obtain a warrant to search Location History, though it emphasizes privacy rather than property as the relevant framework. It separately argues that the Stored Communications Act requires a warrant for Location History because Location History qualifies as “contents” under the statute.

X Corporation also filed an amici brief, but presents a separate argument—that Fourth Amendment protections are rooted in contractual rights. Thus, where a service provider’s contract protects a user’s privacy, a warrant is required to search their data. But if the contract grants no contractual right to privacy, a warrant is not required.

Potential Civil Rights Implications of Geofence Warrants

17 amicus briefs were filed by groups with concerns around civil liberties and privacy. Some of the prevailing arguments are below.

A few briefs identify the risk of error and wrongful arrests with geofence warrants. The brief filed by the Liberty Justice Center argues that the Fourth Amendment reasonableness of geofence warrants is incorrectly premised on the accuracy of the technology. Another filed by the Innocent Project argues that geofence warrants also exacerbate cognitive bias. Both briefs identify cases that led to false arrests, including one where a bicyclist’s Location History was gathered by a geofence warrant and used to place him at the scene of a murder, when he was simply biking past the scene at the time.

Many amicus briefs are concerned with the civil rights implications of allowing geofence warrants, emphasizing government surveillance and threats to First Amendment rights. On the topic of surveillance, a brief filed by the Center for Democracy and Technology, along with others, warned that such warrants could bring pervasive dragnet surveillance. They claim that allowing geofence warrants would “normalize suspicionless fishing expeditions across the digital landscape.” A brief filed by eight law professors with expertise in the Fourth Amendment and digital surveillance detailed the types of invasive reverse searches that could become commonplace as a result of allowing geofence warrants, including keyword searches, artificial intelligence chatbots, cloud searches, and people and object recognition in video and image surveillance. A brief filed by the Constitutional Accountability Center argues that the Fourth Amendment requires judicial oversight of any surveillance technique, and that a lack thereof endangers people’s right to be secure in their persons and property.

On the topic of First Amendment rights, the Center for Democracy and Technology brief also warned against the possibility of chilling critical associates and activities. A brief filed by NetChoice similarly warns of a chilling effect on free expression and free enterprise. A second brief filed by the Project for Privacy and Surveillance Accountability, Inc warned of the dangers to religious freedom and associational rights as a result of enabling “surreptitious mass intrusions into sensitive spaces.” In a similar vein, the brief filed by the Reporters Committee for Freedom of the Press and others argued that geofence warrants implicate First Amendment searches, citing newsgathering, speech, and association as areas that come under threat with the use of geofence warrants. A brief filed by the New Civil Liberties Alliance argued that geofenced location is “precise, detailed, and encyclopedic” and therefore reveals details of one’s private life.

The Impacts

Since the central questions at hand concern Fourth Amendment applicability to modern-day digital data, Chatrie could have consequences well beyond the specific context of geofence warrants. Due to the Supreme Court’s narrow and scarce rulings surrounding the Fourth Amendment, the case may become a broader vehicle for defining constitutional limits regarding technology. If the Court accepts the government’s position, the decision could mark a shift away from recent Fourth Amendment cases, such as Riley v. California and Carpenter v. United States, that have limited law enforcement’s ability to use new technology to obtain information. Subsequently, such a ruling could give law enforcement latitude to use emerging investigative tools, potentially in some circumstances without a warrant.

By contrast, if the Court accepts Chatrie’s arguments, the decision could do more than restrict geofence warrants alone. It could limit law enforcement’s ability to use “reverse warrants” to search digital databases in hopes of generating investigative leads. Although Google’s recent decision to migrate Location History data away from its own servers and onto individual devices will inhibit its ability to respond to geofence warrants, the central privacy questions of this case may apply in other settings. Ultimately, Chatrie will likely determine whether courts treat these technologies as a permissible extension of ordinary warrants, or as a modern analogue to the general warrants the Fourth Amendment was designed to forbid.