Geofence and Keyword Warrants

A geofence warrant does not name a suspect. It asks a company, usually Google, to search its entire Location History database for every device that passed through a place during a window of time, and then hand over identifying information for the ones police want to look at further. A keyword warrant works the same way but searches for everyone who typed a specific term into a search bar. Both flip the usual order of a warrant: instead of identifying a suspect first and then searching, the search itself is how the suspect gets identified. That is the feature critics call the "general warrant" problem, and it is what the courts have spent the last several years sorting out.

This is the fastest-moving fact in this article, decided on June 29, 2026, only weeks before this piece was written, and the official opinion could not be independently verified from the Court's own PDF at the time of publication. The holding above is attributed to reporting on the decision from SCOTUSblog and the Electronic Frontier Foundation, among other outlets, rather than presented as a directly confirmed reading of the slip opinion. Readers relying on this for anything consequential should check the Court's own text, linked in the citation above, for the current, authoritative wording.

A case that took four years to reach the Court

Chatrie had an unusually long road. A federal district court in Virginia found in 2022 that the geofence warrant used to identify Okello Chatrie violated particularity and probable-cause requirements, but let the evidence in anyway under the good-faith exception to the exclusionary rule. A Fourth Circuit panel affirmed in 2024, over a dissent. Then, sitting en banc in 2025, the full Fourth Circuit split evenly on whether a Fourth Amendment search had even occurred, an unusual non-precedential deadlock that left the district court's judgment standing without resolving the underlying question. The Supreme Court granted review in January 2026 and is reported to have decided the case on June 29, 2026, vacating the Fourth Circuit's en banc judgment and remanding it.

The Fifth Circuit went further, and that tension hasn't gone away

Even taking the reported Chatrie holding at face value, it answers only the threshold question: acquiring this kind of location data is a search subject to Fourth Amendment scrutiny. It does not say that any particular geofence warrant fails that scrutiny. That is a narrower ruling than what the Fifth Circuit reached in United States v. Smith in 2024. There, the court held categorically that a geofence warrant requiring Google to search across roughly 592 million user accounts to find devices near a Mississippi post office during a one-hour window was an unconstitutional general warrant, "the exact sort of general, exploratory rummaging the Fourth Amendment was designed to prevent." The panel still let the conviction stand, applying the good-faith exception. As of 2026-07-12, it remains to be seen how much of that broader, categorical reasoning survives now that the Supreme Court has weighed in only on the narrower "is this a search" question, leaving the reasonableness of specific warrant designs, including the one at issue in Smith, for lower courts to keep working out case by case.

Keyword warrants raise a related but formally distinct question: instead of asking who was near a place, they ask who searched for a term. As of 2026-07-12, no Supreme Court or circuit-level ruling squarely addresses keyword warrants the way Chatrie addressed geofence and location data, so that remains a separately open question rather than one resolved by analogy. Anyone citing this article on the current state of either doctrine should confirm nothing has moved since this date, given how quickly this area is developing.