# ALPR Fourth Amendment Law Is Fact-Bound and Unsettled The audited authorities do not establish a nationwide categorical rule that all fixed ALPR collection is lawful or unlawful. Duration, density, aggregation, network reach, query particularity, retention, sharing, purpose, and the resulting picture of movement matter. The three principal decisions in the dossier concern different technologies, facts, courts, and procedural postures. ## Chatrie: Supreme Court location-data holding, not an ALPR case On June 29, 2026, the U.S. Supreme Court held that police acquisition of Google Location History was a Fourth Amendment search because a person has a reasonable expectation of privacy in precise cell-phone location information, even for a limited time and even when obtained from a third-party technology company. The Court vacated and remanded for the Fourth Circuit to address particularity, probable cause, and reasonableness questions (primary public record, [Chatrie v. United States](../../web%20archive/2026-07-20/supremecourt.gov/chatrie-v-united-states-25-112.md)). Chatrie does **not** decide ALPR collection. Its relevance is narrower: it rejects the premise that technological location information automatically loses Fourth Amendment protection merely because it covers a limited period or is held by a third party. ## Church: narrow, unpublished Virginia appeal In *Commonwealth v. Church*, the Virginia Court of Appeals reversed suppression on a record of three Flock images over approximately seven minutes and criticized reliance on hypothetical future misuse rather than the facts before the court. The opinion is expressly unpublished and nonprecedential under Virginia law (primary public record, [Commonwealth v. Church](../../web%20archive/2026-07-20/vacourts.gov/commonwealth-v-church-0737-25-1.md)). It does not establish blanket immunity for long-duration, dense, shared, or nationwide ALPR aggregation. ## Schmidt: district-court judgment with a verified appeal, outcome gap In *Schmidt v. City of Norfolk*, the Eastern District of Virginia granted defendants summary judgment on the developed record concerning Norfolk's then-current 176-camera system and generally 21-day retention, while recognizing that more intrusive surveillance could cross a constitutional line (primary public record, [district-court merits order](../../web%20archive/2026-07-20/cases.justia.com/schmidt-v-city-of-norfolk-document-191.md)). Fourth Circuit No. 26-1227 was docketed February 26, 2026, and the appellants filed an opening brief April 13, 2026 (filed litigation document, [appellants' opening brief](../../web%20archive/2026-07-20/ij.org/schmidt-v-norfolk-opening-brief-2026-04-13.md)). The public docket mirror blocked archival access, and no July 20 appellate disposition was independently located. The brief proves filing metadata and party argument, not the appellate court's ultimate ruling. ## Consequence for the Arkansas investigation None of these authorities decides whether a specific Arkansas tenant's collection, retention, sharing topology, or retrospective query is constitutional. The Arkansas record must supply the operational facts: camera density, time span, query scope, vehicle/people attributes, partner and federal access, retention, reasons, audit trails, and downstream enforcement. Vendor newsletters presenting favorable cases are therefore marketing evidence until the underlying opinion and procedural posture are checked; see [[ALPR-Favorable Case Law as Vendor Messaging]]. This page is evidence analysis, not legal advice. ## Open questions - How much historical movement can each Arkansas agency or sharing partner reconstruct in practice, across which networks and retention periods? - What warrant, subpoena, exigency, consent, or policy process—if any—governs retrospective pattern and association searches? - What is the current appellate disposition of *Schmidt* after the April 13, 2026 opening brief?