Chatrie v. United States · ¶113

On this score, today’s decision fails. The majority does not dispute the Fourth Circuit’s good-faith analysis, and nothing in its opinion casts a shred of doubt on that holding. See ante, at 10, n. 4. To overcome the good-faith exception, Chatrie would need to show that either (1) the affidavit supporting the geofence warrant was knowingly or recklessly false, (2) the magistrate rubber-stamped the warrant application, (3) the affidavit was “‘bare bones,’” or (4) the warrant application was so facially deficient that no reasonable officer would rely on it. Leon, 468 U. S., at 923, and n. 24. Yet nothing in the majority opinion touches on any of these matters. Thus, nothing in today’s decision bears on the Fourth Circuit’s good-faith holding. And because that holding independently supports the judgment below, the Court’s opinion is advisory.

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