Chatrie v. United States · ¶134

The geofence procedure in this case did not violate Chatrie’s Fourth Amendment rights under these 20th-century precedents. These precedents hold that a defendant does not have a reasonable expectation of privacy in records that a company generates by virtue of the defendant’s use of its services. This rule has come to be known as the third-party doctrine. The Court articulated this rule in United States v. Miller, 425 U. S. 435 (1976), holding that the police did not violate a defendant’s Fourth Amendment rights when they obtained transaction records from his bank. In reaching this conclusion, Miller emphasized that a bank is not merely a neutral custodian of its customers’ financial information, but rather a party to an ongoing business relationship with them. Id., at 440–441. Thus, when the defendant “voluntarily conveyed” his financial information to a bank by depositing money or…

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