A geofence warrant asks a service provider for records associated with devices detected within a specified area and time, often before investigators know whose account they want. In a California criminal case, the important questions are what provider and data set were involved, what the warrant actually authorized, what was returned, and whether investigators later sought broader location data or identifying account details. A device or account record does not, by itself, prove who carried the device or committed an offense.
A historical example, not a universal process
In one 2019 Google process described by the U.S. Supreme Court, investigators used three stages. Other warrants, providers, and data sets may work differently, and not every geofence request has three stages.
| Stage in the 2019 Google example | What investigators sought | What to compare in a case file |
|---|---|---|
| Initial area-and-time search | Anonymous device identifiers recorded within the specified geographic boundary and time window | The application, map or boundary, dates and times, and the provider’s first return |
| Further location detail | Additional location information for selected devices, which could include records outside the first boundary | Any later request or authorization, selection criteria, expanded time or area, and the resulting return |
| Account identification | Identifying information for another selection of devices | The identifying-account request, any approval or order, which identifiers were selected, and what account records were disclosed |
These stages describe the historical Google procedure in the record before the Court, not a required sequence for every warrant. A returned device identifier, location record, or subscriber account is a lead to examine. It does not alone establish that a particular person carried a phone at a particular time or took part in a crime. The separate question of what location evidence can establish about a device and its user is covered in our cellphone-location evidence guide.
What the courts decided—and left open
In Chatrie v. United States (June 29, 2026), the Supreme Court held that obtaining the defendant’s historical Google Location History through the warrant was a Fourth Amendment search. It did not decide that the particular warrant was valid or invalid, or order suppression. It sent the case back to examine whether probable cause and particularity supported each stage—the first device search, the later location information, and identification—and left the good-faith question open.
The California Court of Appeal’s People v. Meza involved a particular 2019 Google warrant covering six areas. The court found that warrant overbroad and insufficiently particular, but admitted the evidence under the federal good-faith exception in light of the technique’s newness at that time. That result does not decide how a later warrant will be treated.
When California officials use an electronic-information warrant to seek provider records, Penal Code § 1546.1 requires the warrant to describe what may be seized with particularity, specifying time periods, people or accounts, services, and information types as appropriate and reasonable. It also addresses handling unrelated information and lists other authorization paths for electronic information. Whether the applicable requirements and the Fourth Amendment were satisfied depends on the actual process and records.
If information was obtained or retained in violation of the Fourth Amendment or California’s Electronic Communications Privacy Act, Penal Code § 1546.4 provides conditional routes. A person in a trial, hearing, or proceeding may move to suppress under Penal Code § 1538.5. A person targeted by the process or a recipient of it may separately petition the issuing court to modify or void defective process or destroy unlawfully obtained information. The grounds and procedure matter; neither section promises that evidence will be excluded in a particular case. A notice about an electronic-account search raises a related, separate issue explained in our California account-search notice guide.
Documents to review with counsel
If a geofence search appears in a California case, ask counsel to identify and compare the records that exist:
- The warrant application and affidavit, including the requested location, time window, provider, service, and data types.
- The issued warrant, attachments, maps, amendments, and any later court authorization.
- The provider’s actual return and any requests for further location detail or account identification.
- The identifiers or accounts selected at each stage and the information disclosed.
- The case evidence used to connect a device or account to a person and the alleged conduct.
The documents may not all exist or be available to the person at the same time. Their wording, sequence, and scope can help counsel assess what was authorized and what was actually obtained. Do not assume that a historical Google Location History record is currently available: Chatrie reports that Google moved Location History to users’ devices in July 2025 and represented that it could no longer produce that data set in response to geofence warrants. That statement does not establish that all location records are unavailable or describe another provider’s system. The provider, data set, dates, warrant, and return in the particular case control what can be assessed.
If you or someone close to you is facing a California criminal case involving location records, the Law Offices of David S. Chesley can discuss the case documents with you. Call (800) 755-5174.