Expert Review Advice

Facts of the Case

On May 20, 2019, a man robbed a credit union in Midlothian, Virginia. Investigators interviewed witnesses and reviewed surveillance video. The footage showed the suspect carrying and apparently using a cellular telephone before the robbery, but investigators were unable to identify the suspect through traditional investigative methods.

Detectives obtained a geofence warrant directed to Google. The warrant required Google to search its Location History database and identify every device located within approximately 150 meters of the credit union during the relevant time period.

The warrant operated in three stages:

1. Google produced anonymized location data for every qualifying device within the geofence.
2. Investigators narrowed the list based on movement patterns, and Google provided additional anonymous location data.
3. After investigators identified several devices of interest, Google disclosed subscriber information associated with those accounts.

The investigation ultimately identified Okello Chatrie, whose movements were consistent with those of the robber. Additional investigation linked Chatrie to the robbery, and he was prosecuted in federal court.

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Chatrie filed a Motion to Suppress the location data obtained through the geofence warrant, asserting that the obtaining of his cell phone location data was serch under the Fourth Amendment and that the warrant obtained by law enforcement lacked probable cause.

The District Court found that the geofence warrant "plainly violates the Fourth Amendment" but denied the Motion to Suppress based on the good-faith exception to the exclusionary rule. The Fourth Circuit Court of Appeals affirmed the District Court's ruling on different reasoning, holding that no search occurred because Chatrie "did not have a reasonable expectation of privacy in two hours ' worth of location history data voluntarily exposed to Google". The Supreme Court granted review solely on the question of whether the police violated the Fourth Amendment in obtaining Chatrie's location data.

Supreme Court Holding

On June 29, 2026, the Supreme Court held that law enforcement conducts a Fourth Amendment search when it acquires historical cell-phone location information through a geofence warrant from Google or any other provider. The court concluded that individuals maintain a reasonable expectation of privacy in their historical location information even when the information is stored by a third-party service provider such as Google. The court rejected the government's argument that users automatically lose Fourth Amendment protections simply because their location information is voluntarily shared with a technology company. Importantly, the Court did not decide whether the warrant used in Chatrie ultimately satisfied the Fourth Amendment's probable cause and particularity requirements. Instead, it remanded the case for further proceedings to determine whether the specific geofence warrant in this case met constitutional standards.

Officer Considerations

Officers Should recognize that:

• Accessing historical location data through a geofence warrant is now considered a Fourth Amendment search.
• Even though Google changed Location History in July 2025 so that data stored is stored on individual devices, other companies (Apple, Lyft, Uber, Snapchat, etc...) use location data and this decision extends to location data generally.
• Geofence warrants are subject to constitutional scrutiny including probable cause and particularity requirements
• A Geofence Warrant should be broken down into three separate warrants establishing probable cause for each step of the search.
• Investigators should expect closer judicial review of requests seeking location information involving multiple unknown individuals.
• Applications should be narrowly tailored in geographic scope, time period, and investigative necessity.
• Officers should consult prosecutors and legal advisors before seeking geofence warrants to ensure compliance with evolving constitutional standards.

Practical Impact

This decision does not prohibit geofence warrants. Instead, it requires courts to evaluate under traditional Fourth Amendment standards rather than treating the information as unprotected because it is held by a third party.

Investigators should anticipate increased judicial scrutiny and should ensure affidavits clearly articulate:

• the factual basis established probable cause;
• How the geographic area is related to the crime under investigation;
• That the requested time period is narrowly tailored to the information sought; and
• Why less intrusive methods, if available, would be insufficient to identify a suspect(s).

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By the numbers, the total of ten law enforcement K-9 heatstroke deaths that occurred in 2025 fits right into the historical pattern — more than 2024, but less than 2023, and the same, on average, with the decade prior.

Still, there was a positive development: K-9 heatstroke deaths were more widely and forthrightly acknowledged by law enforcement agencies. This trend of quickly informing the public, and taking more explicit responsibility for these tragedies — most of them avoidable — is a step forward in actively addressing the problem.

2025 K-9 Heatstroke Deaths

As reported in public media

Kai4/23/25Bristol TN PDTraining

Scout5/27/25Suffolk VA PDTracking

Baxter5/28/25Maine DPSIn-vehicle

Henk6/21/25Helen GA PDTraining

Ender6/25/25Dorchester Cty. MD SheriffIn-vehicle

Sam7/8/25Lexington Cty. SC SheriffTraining

Georgia7/13/25Dade Cty. GA SheriffIn-vehicle

Karma8/8/25Isanti Cty. MN SheriffTracking

Archer9/4/25Hawai'i Cty. HI PDIn-vehicle

Cooper9/5/25Muskingum Cty. OH SheriffIn-vehicle

This year, two K-9s died while deployed in tracking, a primary duty of K-9 teams, with recognized risk. The other eight deaths were unrelated to law enforcement action. Three occurred during or soon after organized training events. Five K-9s perished while confined in a vehicle.

Whether deployed at their most instinctual tasks, exercising in-step with their beloved Handler, or secured per protocol inside their specially-equipped duty vehicle — that is to say, practically anywhere in the course of their typical daily activities — healthy K-9's are at risk of suddenly incurring heatstroke and dying. Just as ubiquitously true is that, no one is more shocked and heartbroken by a K-9's heatstroke death than their Handler.

A Hopeful Trend

By the numbers, 2025 K-9 heatstroke deaths and their causes persisted in line with the long-term trend. But important cultural progress was demonstrated by departments' public acknowledgement of most of this year's tragedies. In general the reports were met by immediate social media response that was broadly angry, but also to some extent, sympathetic. Most reports triggered a cascade of external and internal challenges.

Each death was investigated internally, and in some cases, externally. Several Handlers were charged and/or fired outright. Others were disciplined. Probably none will be assigned to police K-9 duty ever again.

The departments took their lumps — public outrage, internal penitence, the loss of the canine's unique policing skills, a disgraced officer, disrepute among K-9 unit funding and support institutions, etc.

Some departments undertook internal review of the policy and protocol failures that may have contributed to the tragedy. One department made their internal findings and corrections public, by declaring policy changes where gaps had been found deficient.

Accepting tough medicine is an important cultural change. Not long ago, most unnecessary K-9 deaths were kept quiet, and responsibility obscured. This tendency persists: one department made a concerted effort to obfuscate a K-9's in-vehicle death. While the officers involved eluded statutory consequence, the department finds itself months later still under a spotlight and still in civil jeopardy, while their oversight governance structure is embarrassed by their inability to implement meaningful accountability.

Acceptance is the First Step

Ultimately, 2025 was another bad year for K-9 heatstroke. But wider acknowledgement of unnecessary K-9 deaths by departments, even in the face of severe consequences, is becoming a strong impetus to finally start acting effectively against heatstroke risk in 2026.

K-9Cooler's mission to AVOID, ALLEVIATE, and PREVENT heat injury to working dogs has inspired development of active-principle products that are effective against heat injury. Visit our store to learn how the K-9 Heatstroke Emergency Field Kit can multiply your K-9's chance of surviving a serious heat injury episode, and save your department from the disgrace of an unnecessary K-9 death.

*Joshua Davidson is the Founder of K-9Cooler, which makes products to AVOID, ALLEVIATE, and PREVENT heat injury to working dogs, including the K-9 Heatstroke Emergency Field Kit.*

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