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Six Law Professors File Amicus Brief Challenging Geofence Warrants in United States v. Okello Chatrie

Bot Mutiny | September 10, 2026

Six law professors filed an amicus curiae brief on September 8, 2026, in the United States Court of Appeals for the Fourth Circuit. The brief supports Okello T. Chatrie in the case United States v. Okello Chatrie, which is currently on remand from the United States Supreme Court. The filing, first reported by CourtListener, argues that geofence warrants empower the government to bypass traditional Fourth Amendment checks. The case, No. 22-4489, centers on the constitutionality of geofence warrants. These warrants allow law enforcement to search for all devices within a specific geographic area during a specific time. The amici, represented by Megan Graham of the University of Iowa College of Law, argue these searches are inherently invasive. ## Expanding Reverse Searches The brief details how a ruling in favor of the government could expand to other forms of "reverse searches." These aren't limited to location data. The professors warn that if geofence warrants are found constitutional, the same logic will apply to reverse keyword searches. In those instances, police search for everyone who typed a specific term into a search engine. This isn't a theoretical concern. The brief cites People v. Seymour, a 2023 Colorado case involving reverse keyword searches. It also points to the growing use of AI chatbots. ## AI Chatbots and Private Data Law enforcement has already begun targeting AI interactions. The brief cites an October 2, 2025, affidavit in United States v. Rinderknect (https://perma.cc/HB5U-YHSA), where investigators sought data from AI providers. With ChatGPT reaching 900 million weekly active users as of February 27, 2026, the volume of private data held by these companies is massive. The professors argue that these AI interactions represent a new frontier for reverse searches. If the government can demand a list of everyone who asked a chatbot a specific question, the privacy of millions of users is at risk. ## The Threat to Cloud and Image Data The filing also identifies cloud storage and facial recognition as high-risk areas. Warrants could be used to scan all files in a cloud provider's database for specific content or to identify every person captured in video surveillance across an entire city. The brief references Leaders of a Beautiful Struggle v. Balt. Police Dep't, a 4th Circuit case involving aerial surveillance, to show the scale of these technologies. The goal of these warrants, the professors argue, is the capturing and commodifying of human experience. ## Constitutional Violations The brief argues that these warrants violate the Fourth Amendment's requirement for particularity. It cites Ybarra v. Illinois, stating that a person's mere proximity to others suspected of criminal activity doesn't give the state a right to search them. The law professors conclude that geofence warrants are "gratuitous" tools that lack appropriate judicial oversight. They argue that upholding the warrant in Chatrie's case would set a precedent allowing the government to rummage through digital lives without specific evidence of wrongdoing by the individuals being searched.