In *Chatrie v. United States*, the case concerned whether police violated the Fourth Amendment by using a geofence warrant to obtain Google Location History data revealing cell phones near a bank robbery, which ultimately identified petitioner Okello Chatrie as a suspect. The Supreme Court held that the police conducted a Fourth Amendment search when they acquired Chatrie’s location data from Google. The Court reasoned that individuals have a reasonable expectation of privacy in the whole of their physical movements as recorded by cell-phone location information, and that Location History provides an even more detailed and revealing record than the cell-site location information at issue in *Carpenter v. United States*. The Court further concluded that the third-party doctrine does not apply to such data, as it is not voluntarily shared in the ordinary sense and is effectively an extension of the user’s private affairs. The Court vacated the judgment below and remanded for the Fourth Circuit to determine whether the multi-step geofence warrant satisfied the Fourth Amendment’s requirements of probable cause and particularity.
In Hunter v. United States, the defendant pleaded guilty to wire fraud under a written plea agreement containing an appeal waiver, then challenged a supervised-release condition requiring him to take prescribed mental-health medications as violating due process; the Fifth Circuit dismissed the appeal, holding that such waivers are enforceable except when tainted by ineffective assistance of counsel or when the sentence exceeds the statutory maximum. The Supreme Court vacated that decision and held that an appeal waiver is unenforceable when enforcing it would produce a miscarriage of justice—i.e., leave in place an egregious error that would bring the judicial system into disrepute. The Court first rejected Hunter’s narrower claim that the district court’s post-sentencing remark about appeal rights and the prosecutor’s silence had modified or forfeited the waiver, because the plea agreement required any modification to be in writing and signed by the parties and because the government’s right to enforce the waiver arises only after an appeal is filed. It then reasoned that because district and appellate courts must approve and implement plea agreements, they have an institutional interest in preventing enforcement of waivers that would cement plainly unlawful sentences (such as those exceeding statutory limits, resting on unconstitutional factors like race, or imposed without basic procedural safeguards), and therefore adopted the miscarriage-of-justice standard already used by most circuits while remanding for the Fifth Circuit to apply it in the first instance.
In Hunter v. United States, petitioner Munson Hunter III pleaded guilty to one count of wire fraud under a written plea agreement that included an appeal waiver, in exchange for dismissal of other charges; at sentencing, the district court imposed a supervised-release condition requiring him to take prescribed mental-health medication, which Hunter sought to challenge on due-process grounds. The Fifth Circuit dismissed the appeal, holding that the waiver remained valid and enforceable except in narrow circumstances such as ineffective assistance of counsel or a sentence exceeding the statutory maximum. The Supreme Court vacated that ruling and held that an appeal waiver is unenforceable when it would produce a miscarriage of justice by leaving in place an egregious, obvious error—such as a sentence based on a constitutionally impermissible factor like race, one exceeding the statutory maximum, or one imposed without minimum civilized procedure—that would bring the judicial system into disrepute. The Court explained that because district courts must approve plea agreements and courts of appeals control enforcement of waivers, the judiciary has an institutional interest in declining to cement plainly unlawful results, even when the waiver was knowing and voluntary. The case was remanded for the Fifth Circuit to decide whether Hunter’s challenge meets this standard.
The case concerned the proper venue for prosecuting a violation of 18 U.S.C. §1519, which criminalizes knowingly falsifying a document with the intent to obstruct a federal investigation. Petitioner Abouammo created and emailed a fake invoice from his home in Seattle during an FBI interview about his disclosure of Twitter user information to a Saudi official; he was indicted and tried in the Northern District of California, where the agents and investigation were based. The Supreme Court held that venue lies only in the district where the falsification occurred, reversing the Ninth Circuit’s affirmance of the conviction. The Court reasoned that constitutional venue protections require trial where the offense’s essential conduct elements took place, and §1519 prohibits only the act of falsification itself—the statute’s mens rea requirement concerning obstructive intent does not incorporate the investigation’s location or any contemplated effects as conduct elements of the crime.
In Abouammo v. United States, the Supreme Court considered the proper venue for prosecuting a violation of 18 U.S.C. §1519, which makes it a crime to knowingly falsify a document with the intent to obstruct a federal investigation. The defendant, Ahmad Abouammo, was indicted in the Northern District of California after creating a fake invoice in Seattle during an FBI interview and emailing it to agents based there; the Ninth Circuit had upheld venue in California because the investigation was located there. The Court held that a defendant charged under the statute must be tried only in the district where the falsification occurred. The reasoning relied on the Constitution’s venue protections, which require trial where the crime was committed, and determined that the statute’s only essential conduct element is the act of falsification itself, while the intent to obstruct is a mens rea requirement that does not expand the location of the offense or allow trial based on contemplated effects elsewhere.
Gabriel Olivier, a street preacher, was convicted in 2021 under a City of Brandon ordinance that confined “protests” and “demonstrations” near an amphitheater to a designated area; after paying a fine and serving probation, he sued the city under 42 U.S.C. §1983 for a declaration and injunction barring future enforcement of the ordinance on First Amendment grounds. The Supreme Court held that the suit could proceed. The Court reasoned that Heck v. Humphrey bars only §1983 claims that would necessarily imply the invalidity of a prior conviction (such as those seeking damages or release), whereas suits requesting wholly prospective relief—here, an injunction against future enforcement—do not collaterally attack the conviction and therefore fall outside Heck’s bar, consistent with Wooley v. Maynard.
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