Chatrie v. United States · ¶31

A divided panel of the Court of Appeals of the Fourth Circuit affirmed, but on different reasoning. The majority held that the government did not conduct a search and therefore did not need a warrant. That was so, the majority reasoned, because Chatrie “did not have a reasonable expectation of privacy in two hours’ worth of Location History data voluntarily exposed to Google.” 107 F. 4th 319, 325 (2024). Judge Wynn dissented, arguing that “the police intrusion into Chatrie’s Location History data” was “a search that triggered the Fourth Amendment’s protections,” and that the warrant issued was “so lacking in particularity and probable cause that it was invalid.” Id., at 339, 362, and n. 12.

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