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VPM News·

Supreme Court restricts geofence warrants after Chesterfield bank robbery case

TL;DR: The U.S. Supreme Court restricted police use of geofence warrants on June 29, 2026, ruling 6-3 that the investigative tool violated the Fourth Amendment in a case stemming from a 2019 Midlothian bank robbery.

Quick facts

  • Who: Okello Chatrie, U.S. Supreme Court, Chesterfield Police and FBI
  • What: Supreme Court ruled geofence warrants violate Fourth Amendment protections
  • When: June 29, 2026 (decision); May 20, 2019 (robbery); April 27, 2026 (oral arguments)
  • Where: Call Federal Credit Union, 10501 Hull Street Road, Midlothian, Virginia

The story

On May 20, 2019, armed robber Okello Chatrie entered the Call Federal Credit Union in Midlothian with a firearm, forced the bank manager to open the safe, and escaped with approximately $195,000 to $196,000 in cash. Chesterfield County Police and the FBI Violent Crime Task Force launched an investigation that would eventually reach the nation's highest court. Detectives obtained a "geofence warrant" and served it on Google, requesting location data on every mobile device that had been within the bank's geographic area during a narrow window of time around the robbery.

The geofence warrant identified Chatrie as a suspect. Based on this evidence, federal prosecutors charged him with armed robbery, forced accompaniment, and brandishing a firearm. In January 2021, Judge M. Hannah Lauck sentenced Chatrie to 141 months (11.75 years) in federal prison, at the low end of sentencing guidelines that ranged from 141 to 155 months. The case gained national attention because the investigative technique it relied on had never been tested in the Supreme Court.

Chatrie challenged the constitutionality of the geofence warrant, arguing it violated his Fourth Amendment protection against unreasonable searches. A Virginia district court initially agreed, finding the warrant unconstitutional, but declined to suppress the evidence based on "good faith" law enforcement reliance on what was then a novel investigative tool. The Fourth Circuit Court of Appeals affirmed that decision in an unusual single-sentence per curiam opinion, followed by 126 pages of concurrences and dissents reflecting deep division among the judges.

On June 29, 2026, the U.S. Supreme Court ruled 6-3 that geofence warrants violate the Fourth Amendment. Writing for the majority, Justice Elena Kagan explained that the technique allows police to "search first and develop suspicions later," subjecting millions of people to warrantless searches despite never having done anything suspicious. The justices agreed a search had occurred but sent the case back to the lower court for further proceedings to determine next steps.

Key players

  • Okello Chatrie: Defendant convicted in armed robbery case that prompted Supreme Court challenge to geofence warrants
  • U.S. Supreme Court: Issued ruling restricting police use of geofence warrants
  • Justice Elena Kagan: Authored majority opinion (6-3 decision)
  • Chesterfield County Police: Investigated the 2019 bank robbery using geofence warrant
  • FBI Violent Crime Task Force: Collaborated with Chesterfield Police on investigation

Key dates

  • 2019-05-20: Call Federal Credit Union robbed in Midlothian
  • 2019-08-13: Okello Chatrie arrested
  • 2021-01-29: Chatrie sentenced to 141 months in federal prison
  • 2026-01-16: Supreme Court granted certiorari in Chatrie v. United States
  • 2026-04-27: Supreme Court heard oral arguments in geofence warrant case
  • 2026-06-29: Supreme Court issued 6-3 ruling restricting geofence warrants

The case for

Geofence warrants allow law enforcement to efficiently narrow a pool of suspects when a crime has been committed, particularly in bank robberies and other serious offenses where speed matters. Without location data analysis, investigators might lack leads in cases where witnesses cannot identify suspects. The targeted warrant approach, requesting data from a specific location during a specific timeframe, can be more precise than traditional canvassing methods and helps focus investigative resources.

The case against

Geofence warrants effectively subject millions of innocent people to warrantless searches by requiring tech companies to hand over the location histories of everyone in an area, not just suspects. This bulk collection treats all residents as potential suspects and violates the principle that the government should have individualized suspicion before searching someone's private data. The technique enables mass surveillance and allows police to engage in reverse-investigative targeting where they collect data first and only develop suspicions afterward, upending traditional Fourth Amendment protections.

Why it matters: The Supreme Court ruling protects the privacy rights of Chesterfield County residents and Americans nationwide by preventing police from using broad geofence warrants that capture innocent people's location data without individualized suspicion. For law enforcement, the decision will require developing more targeted investigative approaches and applying for warrants based on specific suspects rather than mass location sweeps, potentially slowing some investigations but restoring privacy safeguards.

Places

Development timeline

  1. 2019-05-20
    Midlothian bank robbery: Okello Chatrie robs Call Federal Credit Union at 10501 Hull Street Road of approximately $195,000-$196,000 [[source]](https://www.wtvr.com/news/national-news/supreme-court-midlothian-geofence-warrants-call-federal-credit-union-robbery-cellphone-users-case-jan-18-2026)
  2. 2019-08-13
    Suspect arrested: Chesterfield Police and FBI Violent Crime Task Force arrest Okello Chatrie based on geofence warrant investigation [[source]](https://www.wtvr.com/2019/08/14/richmond-man-arrested-in-armed-bank-robbery-in-chesterfield)
  3. 2019-09-18
    Chatrie indicted on federal charges: Grand jury indicts Chatrie on armed robbery charges in connection with $200,000 bank heist [[source]](https://www.wtvr.com/2019/09/18/okello-chatrie-indicted)
  4. 2021-01-29
    Sentencing: Federal Judge M. Hannah Lauck sentences Chatrie to 141 months in prison at the low end of sentencing guidelines [[source]](https://www.justice.gov/usao-edva/pr/man-sentenced-armed-robbery-credit-union)
  5. 2026-01-16
    Supreme Court accepts case: U.S. Supreme Court grants Chatrie's petition for writ of certiorari to review constitutionality of geofence warrant [[source]](https://www.law.cornell.edu/supct/cert/25-112)
  6. 2026-04-27
    Supreme Court oral arguments: Justices hear two hours of arguments on whether geofence warrant violated Fourth Amendment protections [[source]](https://www.scotusblog.com/2026/04/justices-appear-mixed-on-whether-geofence-warrant-violated-the-fourth-amendment-/)
  7. 2026-06-29
    Supreme Court ruling: Court rules 6-3 that geofence warrants violate Fourth Amendment; Justice Kagan writes majority opinion; case remanded to lower court [[source]](https://www.npr.org/2026/06/29/nx-s1-5844697/supreme-court-restricts-use-of-geofence-warrants)

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