The U.S. Supreme Court’s Geofence Ruling Just Landed — Does it Reach Your Google Search History, Too?

In late June 2026, the U.S. Supreme Court decided Chatrie v. United States, holding that police conduct a Fourth Amendment search when they obtain a person’s Google location history through a geofence warrant. It is the most significant digital-privacy decision since Carpenter v. United States, 585 U.S. 296 (2018), and it is going to shape suppression litigation in Indiana for years. This is the first in a series of posts working through what Chatrie means for Hoosier defendants — starting here with the decision itself, and with a question the Court did not answer but that follows naturally from its reasoning: does the same logic protect your Google search history?

What Chatrie Actually Held

The case began with a 2019 bank robbery in Virginia. With no suspect, police obtained a geofence warrant ordering Google to identify every cell phone within 150 meters of the credit union around the time of the crime. The warrant used a three-step funnel: first, anonymized location data for everyone in the zone; then, after police narrowed the list, additional data on a smaller group; finally, names and phone numbers for the remaining suspects. That process eventually identified Chatrie.

The Supreme Court, in an opinion authored by Justice Kagan, held that individuals retain a reasonable expectation of privacy in their Google location history data. First, the data is more granular than cell-site records, in that it is accurate to about twenty meters, logged roughly every two minutes and capable of identifying which floor of a building a phone is on. Second, it allows retrospective reconstruction of a person’s movements with no real effort.

Finally, people treat the data as personally theirs — closer to a private journal than to a business record a company happens to hold. The Court rejected the government’s two main defenses: that a short time window makes the intrusion trivial, and that turning on location history is meaningfully voluntary. Once a privacy interest exists, the Fourth Amendment does not turn on the quality or quantity of what is taken.

Importantly, the Court did NOT decide whether the geofence warrant here satisfied the particularity and probable-cause requirements. It sent that question back to the lower court. So Chatrie answers the threshold question of whether a search occurred, but it left open how the reasonableness analysis for multi-step reverse warrants will shake out.

Why This Matters in Indiana

Two separate points, and it is worth keeping them distinct.

First, the federal floor. Chatrie is now binding Fourth Amendment law nationwide. It does not matter that Indiana has its own search-and-seizure provision. The Fourth Amendment applies in every Indiana courtroom, and evidence obtained in violation of it is subject to suppression regardless of what Article 1, Section 11 of the Indiana Constitution independently requires. Any Indiana case involving a geofence warrant, or genuinely comparable continuous/granular location tracking, now has to clear the bar Chatrie sets.

Second, and more interesting for Indiana practitioners: Article 1, Section 11 does not track the federal analysis at all. Indiana has explicitly rejected the “reasonable expectation of privacy” test that Chatrie is built on. See Litchfield v. State, 824 N.E.2d 356, 361 (Ind. 2005). Instead, Indiana asks whether police conduct was reasonable under the totality of the circumstances, balancing (1) the degree of concern, suspicion, or knowledge that a violation occurred; (2) the degree of intrusion the search imposes on a citizen’s ordinary activities; and (3) the extent of law enforcement’s needs. That means you cannot simply cite Chatrie and expect an Indiana court to import its holding; you have to translate it into Litchfield terms.

No published Indiana appellate decision has ever applied Litchfield to data resembling what was at issue in Chatrie. Nevertheless, Chatrie’s reasoning about why granular, continuous, retrospectively searchable location data is uniquely invasive is directly relevant (and highly persuasive) to the degree-of-intrusion prong of a Litchfield analysis.

Does This Reach Google Search History?

Law enforcement has increasingly used “reverse keyword warrants.” Instead of asking Google for one suspect’s search history, police ask Google to identify everyone who search a particular topic during a given window. It is the same reverse-warrant architecture as a geofence warrant, just querying search terms instead of GPS coordinates.

The leading state case is People v. Seymour, 536 P.3d 1260 (Colo. 2023), where the Colorado Supreme Court recognized a privacy interest in search-engine queries. The Court reasoned that what a person types into a search bar can be even more revealing of the “privacies of life” than where their phone has been, because it captures thoughts and intentions, not just movement.

Apply Chatrie’s own logic to search history and it transfers cleanly, arguable with more force:

• Granularity and intimacy. Chatrie emphasized that location history functions as a personal journal that users treat as their own. A person’s search history is, if anything, a more direct window into their thoughts than where they’ve physically been. It captures curiosity, worry, planning, and intent in the user’s own words.

• Not truly “shared.” Chatrie rejected the idea that opting into a Google feature under repeated, opaque prompts amounts to meaningful voluntary disclosure. The same is true, or more so, of typing a query into a search box. No one believes they are handing their search terms to the government by using Google.

Conclusion

A reverse keyword warrant compelling Google to identify everyone who searched a given term, absent individualized probable cause as to each person swept in, should not survive a Litchfield challenge under Article 1, Section 11. Chatrie supplies the best current judicial language for why. No Indiana appellate court has decided this question yet. This is an argument to be made, not settled law, and I would treat it as a developing area rather than a guaranteed winner. But it is a good-faith, well-supported argument, and it belongs in any suppression motion where the State’s case traces back to a reverse warrant of any kind.

In my next post, I will address what happens when the search is not a location ping or a typed query, but a full conversation with an AI chatbot.