U.S. Court of Appeals for the Fourth Circuit rulings
The Fourth Circuit is the federal appeals court for Maryland, North Carolina, South Carolina, Virginia, and West Virginia. Plain-English summaries from Criminal Defense Resources™; general education, not legal advice.
3 rulings, newest first.
United States v. Chatrie
The full Fourth Circuit affirmed the conviction in a one-sentence unsigned opinion. The judges were evenly divided on whether obtaining the geofence data was a Fourth Amendment search. The U.S. Supreme Court later vacated this decision in Chatrie v. United States (2026).
United States v. Chatrie
A divided Fourth Circuit panel held that no search occurred because the defendant did not have a reasonable expectation of privacy in two hours of Location History data he had voluntarily shared with Google. The full court later reheard the case.
United States v. Graham
The full Fourth Circuit held that the government's acquisition of historical cell-site records from a phone company was not a Fourth Amendment search, applying the third-party doctrine.