Amicus Curiae Brief — Okello T. Chatrie, Petitioner v. United States
Supreme Court briefMar 2, 2026
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No. 25-112
IN THE
SUPREME COURT OF THE UNITED STATES
OKELLO T. CHATRIE,
Petitioner,
v.
UNITED STATES OF AMERICA,
Respondent.
On Writ of Certiorari to the
U.S. Court of Appeals for the Fourth Circuit
BRIEF OF AMICI CURIAE THE REPORTERS
COMMITTEE FOR FREEDOM OF THE PRESS,
KNIGHT FIRST AMENDMENT INSTITUTE AT
COLUMBIA UNIVERSITY, AND FOUNDATION
FOR INDIVIDUAL RIGHTS AND EXPRESSION
IN SUPPORT OF PETITIONER
Nicola Morrow
Jake Karr
Alex Abdo
KNIGHT FIRST
AMENDMENT INSTITUTE
AT COLUMBIA UNIVERSITY
475 Riverside Dr.,
Suite 302
New York, N.Y. 10115
Bruce D. Brown
Counsel of Record
Lisa Zycherman
Gabriel Rottman
Mara Gassmann
Grayson Clary
REPORTERS COMMITTEE FOR
FREEDOM OF THE PRESS
1156 15th St. NW #1020
Washington, D.C. 20005
bruce.brown@rcfp.org
(202) 795-9300
Counsel for Amici Curiae
i
TABLE OF CONTENTS
TABLE OF AUTHORITIES ....................................... ii
INTEREST OF AMICI CURIAE ................................ 1
SUMMARY OF THE ARGUMENT ............................ 3
ARGUMENT ............................................................... 5
I.
Geofence searches implicate important
First Amendment interests.............................5
A. Newsgathering ...........................................6
B. Speech and association ............................11
II. Geofence warrants authorizing the
indiscriminate collection of location
information violate the Fourth
Amendment. ..................................................17
A. Fourth Amendment requirements must
be scrupulously applied when First
Amendment rights are at stake. .............18
B. Geofence warrants fail a
straightforward—let alone scrupulous—
application of the Fourth Amendment’s
requirements. ...........................................22
CONCLUSION .......................................................... 25
ii
TABLE OF AUTHORITIES
Cases
Ams. for Prosperity Found. v. Bonta,
594 U.S. 595 (2021) .......................................... 11, 19
Arizona v. Mayorkas,
143 S. Ct. 1312 (2023) ............................................17
Ashcraft v. Conoco, Inc.,
218 F.3d 282 (4th Cir. 2000)....................................8
Baker v. F & F Inv., 470 F.2d 778
(2d Cir. 1972),
cert. denied, 411 U.S. 966 (1973) .............................8
Branzburg v. Hayes,
408 U.S. 665 (1972) ................................................12
Brown v. Socialist Workers ‘74 Campaign
Comm. (Ohio),
459 U.S. 87 (1982) ..................................................11
Carpenter v. United States,
585 U.S. 296 (2018) ........................ 2, 4, 5, 15, 23, 24
Citizens United v. Fed. Election Comm’n,
558 U.S. 310 (2010) ................................................11
Counterman v. Colorado,
600 U.S. 66 (2023) ............................................ 11, 20
Estes v. Texas,
381 U.S. 532 (1965) ..................................................6
iii
Heller v. New York,
413 U.S. 483 (1973) ................................................21
Kyllo v. United States,
533 U.S. 27 (2001) .............................................. 7, 23
Marcus v. Search Warrants,
367 U.S. 717 (1961) ................................................19
Minneapolis Star & Trib. Co. v. Minn.
Comm’r of Revenue,
460 U.S. 575 (1983) ..............................................7, 8
N.Y. Times Co. v. United States,
403 U.S. 713 (1971) ..................................................8
NAACP v. Alabama ex rel. Patterson,
357 U.S. 449 (1958) .................................... 11, 18, 19
New York v. P.J. Video, Inc.,
475 U.S. 868 (1986) .......................................... 21, 22
Nieves v. Bartlett,
587 U.S. 391 (2019) ................................................21
Nixon v. Adm’r of Gen. Servs.,
433 U.S. 425 (1977) ................................................11
Riley v. California,
573 U.S. 373 (2014) ............................................ 6, 24
Riley v. City of Chester,
612 F.2d 708 (3d Cir. 1979) .....................................8
Roaden v. Kentucky,
413 U.S. 496 (1973) ................................................22
iv
Stanford v. Texas,
379 U.S. 476 (1965) ...........................4, 18-20, 22, 25
Thomas v. Collins,
323 U.S. 516 (1945) ..................................................5
United States v. Chatrie,
107 F.4th 319 (4th Cir. 2024) ..................................1
United States v. Di Re,
332 U.S. 581 (1948) ...................................... 4, 18, 23
United States v. Jones,
565 U.S. 400 (2012) .................................... 19, 23, 24
United States v. Knotts,
460 U.S. 276 (1983) ................................................18
United States v. Ramsey,
431 U.S. 606 (1977) ................................................21
United States v. U.S. Dist. Ct.,
407 U.S. 297 (1972) .................................... 12, 19, 23
Wilkes v. Wood,
19 How. St. Tr. 1153 (C.P. 1763) ...........................19
Ybarra v. Illinois,
444 U.S. 85 (1979) ..................................................24
Zerilli v. Smith,
656 F.2d 705 (D.C. Cir. 1981) ..................................8
Zurcher v. Stanford Daily,
436 U.S. 547 (1978) .................................... 18, 20, 21
v
Other Authorities
Alexander M. Bickel, The Morality of Consent
(1975) ........................................................................7
Amy Mitchell et al., Pew Rsch. Ctr.,
Investigative Journalists and Digital Security
(2015), https://perma.cc/PS6S-VZZT .......................9
Beth LeBlanc, Tracking Michigan Protesters
Raises Privacy, COVID-19 Spread Questions,
Detroit News (June 2, 2020),
https://perma.cc/JL3E-857T ..................................14
Carol Pogash, At Last, Bernstein Meets Deep
Throat, N.Y. Times (Nov. 20, 2008),
https://perma.cc/VY6E-B3E7 ...................................9
Charlie Savage & Katie Benner, Trump
Administration Secretly Seized Phone Records
of Times Reporters,
N.Y. Times (June 2, 2021),
https://www.nytimes.com/2021/06/02/us/trum
p-administration-phone-records-timesreporters.html ........................................................10
Charlie Savage, CNN Lawyers Gagged in Fight
with Justice Dept. over Reporter’s Email Data,
N.Y. Times (June 9, 2021),
https://perma.cc/8LKT-3J3V .................................10
Chris Young & Emily Vespa, The FBI Search of
a Washington Post Reporter’s Home: What We
Know and Why It Matters, Reps. Comm. for
Freedom of the Press (Jan. 16, 2026),
https://perma.cc/W5C3-Y6EM ...............................10
vi
Christian Standard Mag., 2019 Annual Church
Survey (2020), https://perma.cc/8DP3-J7X9 .........16
Daniel J. Solove, The First Amendment as
Criminal Procedure,
82 N.Y.U. L. Rev. 112 (2007) .................................20
Elizabeth Stoycheff, Under Surveillance:
Examining Facebook’s Spiral of Silence Effects
in the Wake of NSA Internet Monitoring,
93 Journalism & Mass Commc’n Q. 296 (2016) ...20
Gabriel Greschler, Phone Data, Surveillance
Used to Monitor San Jose Church That
Violated COVID Rules,
Mercury News (Mar. 8, 2023),
https://www.mercurynews.com/2023/03/08/
phone-data-surveillance-used-to-monitor-sanjose-church-that-violated-covid-rules....................17
George Joseph, Manhattan DA Got Innocent
People’s Google Phone Data Through a
‘Reverse Location’ Search Warrant, Gothamist
(Aug. 12, 2019),
https://perma.cc/RH9K-4BJZ .......................... 14, 15
Government Surveillance: U.S. Has Long
History of Watching White House Critics and
Journalists, Newsweek (July 24, 2017),
https://perma.cc/B76N-3Z6B ...................................7
Hum. Rts. Watch, With Liberty to Monitor All:
How Large-Scale US Surveillance Is Harming
Journalism, Law, and American Democracy
(2014), https://perma.cc/KUH6-4MVF ....................9
vii
Introduction to the Reporter’s Privilege
Compendium, Reps. Comm. for Freedom of
the Press, https://perma.cc/BNT4-HHPY
(last updated Nov. 5, 2021) .................................7, 8
Janny Scott, Now It Can Be Told: How Neil
Sheehan Got the Pentagon Papers,
N.Y. Times (Jan. 7, 2021),
https://perma.cc/NFM7-B76C ..................................9
Jennifer R. Henrichsen & Hannah BlochWehba, Reps. Comm. for Freedom of the
Press, Electronic Communications
Surveillance: What Journalists and Media
Organizations Need to Know (2017),
https://perma.cc/SW4K-EVAX ...............................10
Joe Anuta, With Election Days Away, Mamdani
Turns Canvassing Operation into High Gear,
Politico (Oct. 31, 2025),
https://perma.cc/5Q36-GM8M ...............................13
John & Nisha Whitehead, Geofence
Surveillance: First, They Spied on Protesters.
Then Churches. You’re Next, Rutherford Inst.
(Mar. 15, 2023), https://perma.cc/32UL-UAQX ....17
Joint Appendix,
United States v. Chatrie,
No. 22-4489 (4th Cir. Jan. 20, 2023). ....................16
Jonathon W. Penney, Chilling Effects:
Repression, Conformity, and Power in the
Digital Age (2025) ..................................................20
viii
Joseph Cox, How the U.S. Military Buys
Location Data from Ordinary Apps,
Vice (Nov. 16, 2020),
https://perma.cc/EAX8-2C69 .................................16
Joseph Cox, Leaked Location Data Shows
Another Muslim Prayer App Tracking Users,
Vice (Jan. 11, 2021),
https://perma.cc/T336-HBZJ .................................16
Julie E. Cohen, What Privacy Is For,
126 Harv. L. Rev. 1904 (2013) ...............................20
Mark Harris, A Peek Inside the FBI’s
Unprecedented January 6 Geofence Dragnet,
Wired (Nov. 28, 2022),
https://perma.cc/3JRJ-DY34 ..................................15
Neil M. Richards, The Dangers of Surveillance,
126 Harv. L. Rev. 1934 (2013) ...............................20
Robert McMillan, Kevin Poulsen & Emily
Glazer, Apps Give Trump, Biden Campaigns
Tools to Rally, Track Supporters, Wall St. J.
(Oct. 24, 2020),
https://www.wsj.com/politics/elections/appsgive-trump-biden-campaigns-tools-to-rallytrack-supporters-11603548001 .............................13
Russell Brandom, How Police Laid Down a
Geofence Dragnet for Kenosha Protestors,
Verge (Aug. 30, 2021),
https://www.theverge.com/22644965/kenoshaprotests-geofence-warrants-atf-android-datapolice-jacob-blake ...................................................14
ix
S. Rep. No. 94-755 (1976) ..........................................20
Stuart A. Thompson & Charlie Warzel, Twelve
Million Phones, One Dataset, Zero Privacy,
N.Y. Times (Dec. 19, 2019),
https://perma.cc/W27D-ZHH6 ......................... 12, 16
TPAction’s Brand-New Mobile Application,
Turning Point Action,
https://perma.cc/EG3J-PF9C .................................13
WeBot, Facebook,
https://www.facebook.com/WeBot .........................13
Women’s March Community, Apple App Store,
https://perma.cc/H4P8-A4RV ................................13
Zack Whittaker, Minneapolis Police Tapped
Google to Identify George Floyd Protesters,
TechCrunch (Feb. 6, 2021),
https://perma.cc/ENF4-NJTL ................................14
1
INTEREST OF AMICI CURIAE1
Amici curiae are the Reporters Committee for
Freedom of the Press (“Reporters Committee”),
Knight First Amendment Institute at Columbia
University, and Foundation for Individual Rights and
Expression (“FIRE”) (together, “amici”), organizations
that advocate for the First Amendment rights of the
public and the press.
The Reporters Committee is an unincorporated
nonprofit association founded by leading journalists
and media lawyers in 1970, when the nation’s news
media faced an unprecedented wave of government
subpoenas forcing reporters to name confidential
sources. Today, its attorneys provide pro bono legal
representation, amicus curiae support, and other legal
resources to protect First Amendment freedoms and
the newsgathering rights of journalists. As an
organization that defends the rights of journalists and
news organizations, the Reporters Committee often
appears as amicus curiae in federal courts, as it did
before the Court of Appeals at the panel and en banc
stages in this case, to highlight the effects of excessive
surveillance on the confidential reporter-source
relationships that underpin so much public interest
journalism. See United States v. Chatrie, 107 F.4th
319, 372–73 (4th Cir. 2024) (Wynn, J., dissenting)
(citing Br. of Amicus Curiae Reps. Comm. for Freedom
of the Press in Supp. of Def.-Appellant at 7–8, No. 224489 (4th Cir. Jan. 27, 2023)); Br. of Amicus Curiae
Reps. Comm. for Freedom of the Press in Supp. of
1 Pursuant to Supreme Court Rule 37, counsel for amici curiae
state that no partys counsel authored this brief in whole or in
part; no party or partys counsel made a monetary contribution
intended to fund the preparation or submission of this brief; and
no person other than the amici curiae, their members or their
counsel made a monetary contribution intended to fund the
preparation or submission of this brief.
2
Reh’g En Banc, No. 22-4489 (4th Cir. Aug. 29, 2024);
see also, e.g., Br. of Amici Curiae Reps. Comm. for
Freedom of the Press & 15 Media Orgs., Tuggle v.
United States, 142 S. Ct. 1107 (2022) (No. 21-541); Br.
Amici Curiae of Reps. Comm. for Freedom of the Press
& 19 Media Orgs., Carpenter v. United States, 138 S.
Ct. 2206 (2018) (No. 16-402); En Banc Br. of Amici
Curiae Reps. Comm. for Freedom of the Press & 8
Media Orgs., United States v. Moore-Bush, 36 F.4th
320 (1st Cir. 2022) (Nos. 19-1582, 19-1625, 19-1583,
19-1626); Br. of Reps. Comm. for Freedom of the
Press, Thomas Jefferson Ctr. for Prot. of Free
Expression & 17 Media Orgs. as Amici Curiae,
Wikimedia Found. v. Nat’l Sec. Agency, 857 F.3d 193
(4th Cir. 2017) (No. 15-2560).
The Knight First Amendment Institute at
Columbia University is a non-partisan, not-for-profit
organization that defends the freedoms of speech and
the press in the digital age through strategic
litigation, research, policy advocacy, and public
education. The Institute’s aim is to promote a system
of free expression that is open and inclusive, that
broadens and elevates public discourse, and that
fosters creativity, accountability, and effective selfgovernment. The Institute is particularly committed
to upholding constitutional limits on government
surveillance that chills core First Amendment
activities, and it frequently litigates cases and
appears as amicus curiae in federal courts to
challenge surveillance that unduly burdens protected
association and expression. See, e.g., United States v.
Belmonte Cardozo, No. 25-4239 (4th Cir. Oct. 28,
2025) (amicus) (cellphone searches at the border); Doc
Soc’y v. Rubio, 141 F.4th 1273 (D.C. Cir. 2025)
(counsel) (social media registration); Wikimedia
Found. v. Nat’l Sec. Agency, 857 F.3d 193 (4th Cir.
3
2017)
(counsel)
communications).
(surveillance
of
Internet
FIRE is a nonpartisan nonprofit that defends
the individual rights of all Americans to free speech
and free thought—the essential qualities of liberty.
Since 1999, FIRE has successfully defended First
Amendment rights nationwide through public
advocacy and targeted litigation. FIRE represents
speakers, without regard to their political views, in
lawsuits across the United States. See, e.g., Spectrum
WT v. Wendler, 151 F.4th 714, reh’g en banc granted,
157 F.4th 673 (5th Cir. 2025); Volokh v. James, 148
F.4th 71 (2d Cir. 2025), certified questions accepted,
267 N.E.3d 1245 (N.Y. 2025); Fellowship of Christian
Univ. Students at Univ. of Tex. at Dallas v. Eltife, No.
1:25-cv-1411, 2025 WL 2924228 (W.D. Tex. Oct. 14,
2025). FIRE has a particular interest in this case
because it regularly defends the First Amendment
rights of speakers, including journalists, targeted by
the government for viewpoint-based retaliation. See,
e.g., Villarreal v. Alaniz, 145 S. Ct. 368 (2024), on
remand, 134 F.4th 273 (5th Cir. 2025), cert. petition
filed, No. 25-29 (July 7, 2025); Volokh v. Chiu, No.
3:24-cv-08343 (N.D. Cal. filed Nov. 22, 2024); Rosado
v. Bondi, No. 1:26-cv-01532 (N.D. Ill. filed Feb. 11,
2026).
SUMMARY OF THE ARGUMENT
Armed with a geofence warrant, government
investigators can comb through the location histories
of millions to expose the movements of every
individual present in a given area during a given time
period. That license to cast an indiscriminate and
4
retrospective dragnet over any location—without any
individualized suspicion—poses obvious threats to
First Amendment rights, including the ability of
journalists to gather confidential information and
inform the public, and of citizens to speak on matters
of public concern and engage in political or religious
association. Should the Court adopt the government’s
position, law enforcement investigating any
purported crime could obtain a warrant authorizing
the surveillance of anyone visiting a nearby
newsroom, marching in protest on the streets outside,
or gathering to pray in the house of worship next door.
The Fourth Amendment was meant to serve as
a bulwark against this “stifling” of “liberty.” Stanford
v. Texas, 379 U.S. 476, 482–85 (1965) (citation
omitted). For that reason, the Court has required an
especially rigorous application of the Fourth
Amendment’s requirements when First Amendment
rights are at stake. And in recent cases, the Court has
warned that modern location-tracking technologies
can enable a “too permeating police surveillance” that
threatens constitutionally protected activities and
associations. Carpenter v. United States, 585 U.S.
296, 305 (2018) (quoting United States v. Di Re, 332
U.S. 581, 595 (1948)).
Geofence warrants should founder against this
bulwark. Unlike cell-site location information or GPS
tracking of a vehicle, the location data obtained
through a geofence search does not merely “provide[]
an intimate window” into the life of a single, specific
suspect, id. at 311; it reveals the movements,
activities, and associations of every person, journalist
and passerby alike, who happens to have been present
5
near the site and around the time of a suspected
crime. Nor do geofence warrants target individuals
suspected of criminality, as is the case with every
advanced form of surveillance this Court has ever
authorized; instead, they sanction searches in reverse,
ensnaring everyone to develop the individualized
suspicion that might have justified the search of
someone in the first instance. The Court should
interrogate the constitutionality of geofence warrants
with acute attention to this unprecedented power and
the dangers it poses to discrete First Amendment
freedoms and all the various ways in which they are
interconnected. “It was not by accident or coincidence
that the rights to freedom in speech and press were
coupled in a single guaranty with the rights of the
people peaceably to assemble and to petition for
redress of grievances. All these, though not identical,
are inseparable.
They are cognate rights, and
therefore are united in the First Article’s assurance.”
Thomas v. Collins, 323 U.S. 516, 530 (1945) (citations
omitted).
The totality of the impact on these
constitutional freedoms compels the conclusion that
the geofence warrant used by the government in its
investigation of Okello Chatrie violated the Fourth
Amendment.
ARGUMENT
I.
Geofence searches implicate important
First Amendment interests.
The phones most people carry today generate
detailed and sensitive location data wherever they go,
providing
comprehensive
accounts
of
their
movements over time. See Carpenter, 585 U.S. at 314
6
(noting “the exhaustive chronicle of location
information casually collected by wireless carriers
today”); Riley v. California, 573 U.S. 373, 396 (2014)
(“Historic location information is a standard feature
on many smart phones and can reconstruct someone’s
specific movements down to the minute, not only
around town but also within a particular building.”).
Geofence searches take advantage of these vast
repositories by indiscriminately sweeping up the
location data of anyone who happens to be carrying a
phone near the site of suspected criminal activity.
These dragnets inevitably reveal not just the
movements of those ensnared, but also a wealth of
sensitive information about their expressive activities
and associations—from journalists interviewing
confidential sources, to protesters attending rallies, to
congregants attending religious services. The ability
to cast a net at any time and around any location—
without the need for individualized suspicion or
particularity—poses obvious threats to these First
Amendment interests.
A. Newsgathering
Geofence searches can intrude on the First
Amendment rights of the press to obtain and publish
news and information, and of the public to receive
such information. The press historically “has been a
mighty catalyst in awakening public interest in
governmental affairs, exposing corruption among
public officers and employees and generally informing
the citizenry of public events and occurrences.” Estes
v. Texas, 381 U.S. 532, 539 (1965). Geofence searches
can interfere with that role, and the newsgathering
process, by exposing stories pursued, journalistic
7
methods employed, and, most critically, the identities
of sources consulted. Journalists regularly rely on
confidential sources in fulfilling their role as “an
important restraint on government,” Minneapolis
Star & Trib. Co. v. Minn. Comm’r of Revenue, 460 U.S.
575, 585 (1983), and sources often demand anonymity
out of fear that—if their identities are revealed—they
will face prosecution, loss of employment, or even
threats to their lives.2 Because in-person meetings
play a crucial role in reporter-source relationships,
location tracking has long been a tool employed by
officials hoping to investigate and ultimately chill
communications with the media.3 But the “more
sophisticated” tracking, Kyllo v. United States, 533
U.S. 27, 36 (2001), enabled by geofence searches has
expanded investigators’ field of view dramatically
and, if the Fourth Circuit is not reversed, risks
deterring sources from speaking to journalists for fear
of exposure.
Virtually every state provides some protection
for journalists from being compelled to identify
confidential sources or disclose newsgathering
material (either through statute or the common law),
See Introduction to the Reporter’s Privilege Compendium,
Reps. Comm. for Freedom of the Press, https://perma.cc/BNT4HHPY (last updated Nov. 5, 2021); Alexander M. Bickel, The
Morality of Consent 84 (1975) (observing that “[i]ndispensable
information comes in confidence from” a great variety of people
in many different positions).
2
See Government Surveillance: U.S. Has Long History of
Watching White House Critics and Journalists, Newsweek (July
24, 2017), https://perma.cc/B76N-3Z6B (noting the CIA’s track
record of “follow[ing] newsmen . . . in order to identify their
sources”).
3
8
and most of the federal courts of appeals afford some
qualified protection for journalist materials and
sources. See Introduction to the Reporter’s Privilege
Compendium, supra. These protections are necessary
because, “[i]f reporters were routinely required to
divulge the identities of their sources, the free flow of
newsworthy information would be restrained and the
public’s understanding of important issues and events
would be hampered in ways inconsistent with a
healthy republic.” Ashcraft v. Conoco, Inc., 218 F.3d
282, 287 (4th Cir. 2000) (citing Minneapolis Star &
Trib. Co., 460 U.S. at 585 (“An untrammeled press is
a vital source of public information, and an informed
public is the essence of working democracy.”)); see
also, e.g., Zerilli v. Smith, 656 F.2d 705, 710–11 (D.C.
Cir. 1981) (“Without an unfettered press, citizens
would be far less able to make informed political,
social, and economic choices. But [its] function as a
vital source of information is weakened whenever the
ability of journalists to gather news is impaired.”
(citing N.Y. Times Co. v. United States, 403 U.S. 713,
717 (1971) (Black, J., concurring))); Riley v. City of
Chester, 612 F.2d 708, 714 (3d Cir. 1979) (recognizing
the “interrelationship between newsgathering, news
dissemination and the need for a journalist to protect
his or her source”); Baker v. F & F Inv., 470 F.2d 778,
782 (2d Cir. 1972) (“Compelled disclosure of
confidential sources unquestionably threatens a
journalist’s ability to secure information that is made
available to him only on a confidential basis[.]”), cert.
denied, 411 U.S. 966 (1973).
Journalists rely on sources of information to
uncover the truth and report the news, and sometimes
their source relationships are so sensitive that they
9
meet in person.4 The reporting of the landmark
Pentagon Papers disclosures, for instance, involved
repeated confidential meetings between Neil Sheehan
of The New York Times and his source, Daniel
Ellsberg, at each other’s homes.5
In another
historically significant example, Bob Woodward met
Mark Felt in an underground parking garage and had
discussions that led to The Washington Post’s
exposure of the Watergate story.6 The value of the
reporting that would be lost if journalists could not
credibly guard the confidentiality of those contacts
cannot be overstated.
Thus, in-person meetings have always played a
role in reporter-source relationships. And those
interactions have taken on special importance in
Amy Mitchell et al., Pew Rsch. Ctr., Investigative
Journalists
and
Digital
Security
8–9
(2015),
https://perma.cc/PS6S-VZZT (“When it comes to the specific
actions journalists may or may not take to protect their sources,
the most common technique by far . . . is to meet them in
person.”); Hum. Rts. Watch, With Liberty to Monitor All: How
Large-Scale US Surveillance Is Harming Journalism, Law, and
American Democracy 4 (2014), https://perma.cc/KUH6-4MVF
(finding that growing awareness of government monitoring has
led journalists “to adopt elaborate steps to protect sources and
information,” up to and including “abandoning all online
communication and trying exclusively to meet sources in
person”).
4
See Janny Scott, Now It Can Be Told: How Neil Sheehan
Got the Pentagon Papers, N.Y. Times (Jan. 7, 2021),
https://perma.cc/NFM7-B76C.
5
See Carol Pogash, At Last, Bernstein Meets Deep Throat,
N.Y. Times (Nov. 20, 2008), https://perma.cc/VY6E-B3E7.
6
10
today’s climate of pervasive electronic surveillance.7
The tactics of multiple federal administrations
provide a vivid reminder that the electronic trail left
by journalists when they interact with their sources is
only a secret court order away from government
scrutiny.8
Notably,
the
current
federal
administration has weakened Justice Department
policies that had imposed stringent guardrails on the
ability of officials pursuing leak investigations to seek
these kinds of electronic records from journalists.9
When any stray digital breadcrumb could put a
person’s identity at risk, journalists have been forced
to find offline ways to interact with sources and obtain
information, and in-person meetings provide a crucial
safety valve by which that information can reach the
public.
See generally Jennifer R. Henrichsen & Hannah BlochWehba, Reps. Comm. for Freedom of the Press, Electronic
Communications Surveillance: What Journalists and Media
Organizations Need to Know (2017), https://perma.cc/SW4KEVAX.
7
See, e.g., Chris Young & Emily Vespa, The FBI Search of
a Washington Post Reporter’s Home: What We Know and Why It
Matters, Reps. Comm. for Freedom of the Press (Jan. 16, 2026),
https://perma.cc/W5C3-Y6EM; Charlie Savage & Katie Benner,
Trump Administration Secretly Seized Phone Records of Times
Reporters,
N.Y.
Times
(June
2,
2021),
https://www.nytimes.com/2021/06/02/us/trump-administrationphone-records-times-reporters.html; Charlie Savage, CNN
Lawyers Gagged in Fight with Justice Dept. over Reporter’s
Email Data, N.Y. Times (June 9, 2021), https://perma.cc/8LKT3J3V.
8
Of course, even when they were in effect under the
previous administration, these policies provided no protection
against investigations conducted by state or local governments.
9
11
The investigative technique at issue in this
case, however, threatens to erode this safe harbor for
confidentiality. Not only could a geofence search
incidentally capture the next Neil Sheehan visiting
the home of the next Daniel Ellsberg, or the next Deep
Throat providing critical information to a future
Woodward and Bernstein, but investigators could use
any suspected crime near a newsroom as a pretext to
identify everyone who visited that day.
B. Speech and association
The ability to report and receive the news is not
the only First Amendment right put at risk by
government abuse of geofence searches. They also
directly implicate the association and expression that
are “central to the meaning and purpose of the First
Amendment,” Citizens United v. Fed. Election
Comm’n, 558 U.S. 310, 329 (2010).
This Court has long protected participation in
peaceful protest, see Counterman v. Colorado, 600
U.S. 66, 81 (2023) (noting that “dissenting political
speech” lies “at the First Amendment’s core”), and
“involvement in partisan politics,” Nixon v. Adm’r of
Gen. Servs., 433 U.S. 425, 467 (1977). It has rejected
government attempts to unmask and surveil those
engaged in protected political activity, Ams. for
Prosperity Found. v. Bonta, 594 U.S. 595, 616 (2021),
or those “espous[ing] dissident beliefs,” NAACP v.
Alabama ex rel. Patterson, 357 U.S. 449, 462 (1958);
see Brown v. Socialist Workers ‘74 Campaign Comm.
(Ohio), 459 U.S. 87, 99–100 (1982) (protecting minor
political party from forced disclosure of donors
because of “past history of government harassment”
12
and
“hostility,”
including
“massive”
“FBI
surveillance”). Geofence searches, however, risk
allowing the government to circumvent these
constitutional limits, both with respect to the
individuals engaged in this activity and the
journalists covering it. See Branzburg v. Hayes, 408
U.S. 665, 672–75 (1972) (analyzing journalist’s
privilege not to testify in three separate cases, two of
which involved reporters covering the Black Panthers
and other civil rights groups).
When journalists are out in the field reporting
on demonstrations, for example, geofence searches
can sweep up the location data of these reporters, as
well as the political protesters and campaigners they
are covering and who are being subjected to law
enforcement scrutiny simply because they happened
to attend a political demonstration or canvass a
neighborhood near a suspected crime. See United
States v. U.S. Dist. Ct., 407 U.S. 297, 320 (1972)
(noting the “temptation to utilize” government
surveillance “to oversee political dissent”). During the
2016 presidential inauguration, for example, an
independent investigation demonstrated how location
data from a variety of sources “yielded a trove of
personal stories and experiences,” from “elite
attendees at presidential ceremonies” and “supporters
assembling
across
the
National
Mall”
to
“[p]rotesters”—“all
surveilled
and
recorded
permanently in rigorous detail.”10
This risk is
Stuart A. Thompson & Charlie Warzel, Twelve Million
Phones, One Dataset, Zero Privacy, N.Y. Times (Dec. 19, 2019),
https://perma.cc/W27D-ZHH6 (“After the pings of Trump
supporters, basking in victory, vanished from the National Mall
on Friday evening, they were replaced hours later by those of
10
13
exacerbated by the increasing use of digital tools for
political mobilization that collect location data.
Activists use location-based apps and websites to find
demonstrations in their areas,11 while political
campaigns rely on apps that collect the location data
of their staff, volunteers, and voters, allowing
canvassers to identify which houses to visit.12
Law enforcement has already accessed this sort
of location data in ways that will predictably burden
political advocacy (and the journalists who cover it).
During the summer of 2020, for instance, law
enforcement agencies across the country obtained the
participants in the Women’s March, as a crowd of nearly half a
million descended on the capital.”).
See,
e.g.,
WeBot,
Facebook,
https://www.facebook.com/WeBot (sharing reminders and
information about protests near user); Women’s March
Community, Apple App Store, https://perma.cc/H4P8-A4RV
(helping activists “take meaningful action” and “connect with
members near you”).
11
See, e.g., TPAction’s Brand-New Mobile Application,
Turning Point Action, https://perma.cc/EG3J-PF9C (providing
“door knocking routes” and other tools to “easily find voters near
you”); Joe Anuta, With Election Days Away, Mamdani Turns
Canvassing Operation into High Gear, Politico (Oct. 31, 2025),
https://perma.cc/5Q36-GM8M (describing use of location-based
“app allowing door knockers to reach their targets”); Robert
McMillan, Kevin Poulsen & Emily Glazer, Apps Give Trump,
Biden Campaigns Tools to Rally, Track Supporters, Wall St. J.
(Oct. 24, 2020), https://www.wsj.com/politics/elections/apps-givetrump-biden-campaigns-tools-to-rally-track-supporters11603548001 (describing presidential campaign apps that
“organize volunteers” and “identify users who attend a particular
event or travel to a particular location with the app installed on
their device”).
12
14
location data of thousands of individuals engaged in
largely peaceful protests. In Lansing, Michigan, a
liberal advocacy group acquired and then shared with
state law enforcement the location data of hundreds
of individuals who attended an American Patriots
Rally to protest their governor’s COVID-19 pandemic
stay-at-home orders.13 In Kenosha, Wisconsin, law
enforcement investigating “minimal fire damage” at a
public library “set a two-hour window and a geofence
covering the middle third of the downtown’s largest
public park space,” indiscriminately collecting
location data “on the busiest night of the protest.”14 In
Minneapolis, Minnesota, a bystander who had
recorded a protest received an email from Google
informing him that his location data “was subject to [a
geofence] warrant, and would be given to the police.”15
A year earlier, the Manhattan District Attorney
conducted a geofence search in an attempt to identify
victims of a suspected crime that occurred during a
clash of left-wing and right-wing activist groups.16
Beth LeBlanc, Tracking Michigan Protesters Raises
Privacy, COVID-19 Spread Questions, Detroit News (June 2,
2020), https://perma.cc/JL3E-857T.
13
Russell Brandom, How Police Laid Down a Geofence
Dragnet for Kenosha Protestors, Verge (Aug. 30, 2021),
https://www.theverge.com/22644965/kenosha-protests-geofencewarrants-atf-android-data-police-jacob-blake.
14
Zack Whittaker, Minneapolis Police Tapped Google to
Identify George Floyd Protesters, TechCrunch (Feb. 6, 2021),
https://perma.cc/ENF4-NJTL.
15
George Joseph, Manhattan DA Got Innocent People’s
Google Phone Data Through a ‘Reverse Location’ Search
Warrant, Gothamist (Aug. 12, 2019), https://perma.cc/RH9K4BJZ.
16
15
The geofence swept up the data of protesters, counterprotesters, and local residents alike in one of the most
densely populated urban areas in the country.17
Perhaps the most well-known example is the
geofence search conducted by the FBI in its
investigation of those who stormed the U.S. Capitol on
January 6, 2021. The FBI sought data on all devices
over a 4.5-hour period located within a four-acre area
that included not only the building itself but also its
surroundings.18 While the predicate for the FBI
investigation was suspected criminal activity in and
immediately around the Capitol, this wide net also
inevitably swept up information on individuals who
were protesting lawfully, as well as many journalists
who covered the incident.19
Geofence searches likewise threaten religious
association. In much the same way that geofence
searches can be used to expose journalists and
confidential sources or surveil political activists and
dissidents, a geofence search conducted near a church,
a synagogue, or a mosque could identify anyone who
brought a phone to services. See Carpenter, 585 U.S.
Id. (“Court records show that this dragnet data request
captured the location data of multiple people who were put under
law enforcement scrutiny, even though they had nothing to do
with the crimes under investigation.”).
17
Mark Harris, A Peek Inside the FBI’s Unprecedented
January 6 Geofence Dragnet, Wired (Nov. 28, 2022),
https://perma.cc/3JRJ-DY34.
18
19
Id.
16
at 311 (location
associations).20
data
can
reveal
religious
This threat is not hypothetical. The geofence
search in this very case encompassed Journey
Christian Church, a “mega church” in Midlothian,
Virginia that at the time hosted over 1,500 weekly
attendees at its services. See JA-160.21 Indeed, most
of the devices swept up in the initial geofence search
appear to have been located within the church. JA2003–07, JA-2013–16, United States v. Chatrie, No.
22-4489 (4th Cir. Jan. 20, 2023), Doc. No. 19-8.
Despite this disproportionate impact on religious
association, the warrant application did not even
mention the church, referring to it merely as “an
adjacent business.” JA-131. And at the height of the
COVID-19 pandemic, a county in California went
even further, deliberately targeting religious
worshippers by using “mobile phone data to map
concentrations of congregants gathering on the . . .
grounds” of Calvary Chapel, a church in San Jose that
state officials suspected of violating stay-at-home
rules, including “data that specifically captured
movement within the boundaries of the church’s
See also Thompson & Warzel, supra (location data
revealed “religious observers at church services”). The numerous
apps that collect location data to facilitate users’ religious
observance would be especially sensitive targets. See, e.g.,
Joseph Cox, Leaked Location Data Shows Another Muslim
Prayer App Tracking Users, Vice (Jan. 11, 2021),
https://perma.cc/T336-HBZJ; Joseph Cox, How the U.S. Military
Buys Location Data from Ordinary Apps, Vice (Nov. 16, 2020),
https://perma.cc/EAX8-2C69.
20
See Christian Standard Mag., 2019 Annual Church
Survey 5 (2020), https://perma.cc/8DP3-J7X9.
21
17
property.”22 Cf. Arizona v. Mayorkas, 143 S. Ct. 1312,
1314 (2023) (statement of Gorsuch, J.) (“They
surveilled church parking lots, recorded license
plates, and issued notices warning that attendance at
even outdoor services satisfying all state socialdistancing and hygiene requirements could amount to
criminal conduct.”).
Just as sources may decline to speak with
journalists for fear of talking to a reporter who could
be surveilled, the tracking of citizens engaged in free
speech and political or religious association may
additionally deter such persons from speaking to the
press about their activities, creating a further
impediment to the ability of reporters to obtain
information about matters of public concern regarding
these individuals and their institutions.
II.
Geofence warrants authorizing the
indiscriminate collection of location
information
violate
the
Fourth
Amendment.
The Founders intended Fourth Amendment
protections to guard against the “stifling” of First
Gabriel Greschler, Phone Data, Surveillance Used to
Monitor San Jose Church That Violated COVID Rules, Mercury
News (Mar. 8, 2023), https://www.mercurynews.com/2023/03/08/
phone-data-surveillance-used-to-monitor-san-jose-church-thatviolated-covid-rules; see also John & Nisha Whitehead, Geofence
Surveillance: First, They Spied on Protesters. Then Churches.
You’re
Next,
Rutherford
Inst.
(Mar.
15,
2023),
https://perma.cc/32UL-UAQX (arguing that geofence searches of
“people praying and gathering on church grounds” risk “freefalling into a total surveillance state”).
22
18
Amendment freedoms. Stanford, 379 U.S. at 482–85.
Recognizing this “vital relationship” between privacy,
on the one hand, and protected activities and
associations, on the other, NAACP, 357 U.S. at 462,
the Court has required an especially rigorous
application of the Fourth Amendment’s requirements
when First Amendment rights are at stake, Zurcher
v. Stanford Daily, 436 U.S. 547, 564 (1978). Because
geofence warrants enable searches that as described
above burden First Amendment interests, they must
survive this more rigorous review. But the Court’s
location-tracking precedents make clear that they
cannot. Geofence warrants like the one at issue here
indiscriminately sweep up sensitive location data
without individualized suspicion and they necessarily
cannot “describe the things to be seized . . . [with] the
most scrupulous exactitude.” Stanford, 379 U.S. at
485 (citation omitted).
This “dragnet type law
enforcement practice[,]” United States v. Knotts, 460
U.S. 276, 284 (1983), epitomizes the “too permeating
police surveillance” that undermines “a free people,”
Di Re, 332 U.S. at 595.
A. Fourth Amendment requirements must
be scrupulously applied when First
Amendment rights are at stake.
Since the Founding, the protections of the First
and Fourth Amendments have been closely
intertwined. “The bill of Rights was fashioned against
the background of knowledge that unrestricted power
of search and seizure could also be an instrument for
stifling liberty of expression.” Stanford, 379 U.S. at
482–85 (citation omitted) (describing abusive English
practices targeting the publishers of dissident
19
publications); see also Ams. for Prosperity Found., 594
U.S. at 620 (Thomas, J., concurring) (“Founding-era
Americans understood the freedom of the press to
include the right of printers and publishers not to be
compelled to disclose the authors of anonymous
works.” (citation and internal quotation marks
omitted)).
Lord Camden’s insight—that a
“discretionary power given to messengers to search
wherever their suspicions may chance to fall” is
“totally subversive of the liberty of the subject”—
continues to inform interpretation of the Fourth
Amendment today. Marcus v. Search Warrants, 367
U.S. 717, 728–29 (1961) (quoting Wilkes v. Wood, 19
How. St. Tr. 1153, 1167 (C.P. 1763)).
The Court has repeatedly recognized this link
between “individual privacy” and “free expression”—
and “the potential danger” that “unreasonable
surveillance” poses to each. U.S. Dist. Ct., 407 U.S. at
315–17; see Stanford, 379 U.S. at 482–85 (“The[]
[First, Fourth, and Fifth] [A]mendments are indeed
closely related, safeguarding not only privacy and
protection against self-incrimination but conscience
and human dignity and freedom of expression as
well.” (citation and internal quotation marks
omitted)); NAACP, 357 U.S. at 462 (recognizing “the
vital relationship between freedom to associate and
privacy in one’s associations”). History, social science
research, and common sense all confirm: “Awareness
that the government may be watching chills
associational and expressive freedoms.” United States
v. Jones, 565 U.S. 400, 416 (2012) (Sotomayor, J.,
concurring); Ams. for Prosperity Found., 594 U.S. at
616–17 (finding that California’s donor disclosure
requirement created an unnecessary risk of chilling
20
association by “indiscriminately sweeping up the
information of every major donor”); S. Rep. No. 94-755,
at 17 (1976), https://perma.cc/TNJ9-3X7Y (“[T]he
government’s
surveillance
activities
in
the
aggregate—whether or not expressly intended to do
so—tends . . . to deter the exercise of First
Amend[ment] rights by American citizens who
become aware of the government’s domestic
intelligence program.”).23 Our democracy and public
discourse are impoverished when “ordinary
citizen[s],” seeking to “steer wide[]” of official scrutiny,
Counterman, 600 U.S. at 77–78 (citation and internal
quotation marks omitted), refrain from activities and
associations that are constitutionally protected but
might nonetheless get caught up in the
“indiscriminate sweep” of government surveillance,
Stanford, 379 U.S. at 486.
This Court has thus insisted that Fourth
Amendment review be especially rigorous when First
Amendment interests hang in the balance, especially
in cases involving intrusions on the newsgathering
and reporting process. See Zurcher, 436 U.S. at 564
(“[T]he warrant requirement should be administered
A growing body of social science research illustrates the
causal relationship between pervasive surveillance and chilling
effects in the digital age. See, e.g., Jonathon W. Penney, Chilling
Effects: Repression, Conformity, and Power in the Digital Age 99
(2025); Elizabeth Stoycheff, Under Surveillance: Examining
Facebook’s Spiral of Silence Effects in the Wake of NSA Internet
Monitoring, 93 Journalism & Mass Commc’n Q. 296, 307 (2016);
Neil M. Richards, The Dangers of Surveillance, 126 Harv. L. Rev.
1934, 1950 (2013); Julie E. Cohen, What Privacy Is For, 126
Harv. L. Rev. 1904, 1917 (2013); Daniel J. Solove, The First
Amendment as Criminal Procedure, 82 N.Y.U. L. Rev. 112, 131–
32 (2007).
23
21
to leave as little as possible to the discretion or whim
of the officer in the field.”). Those interests demand a
searching application of the Fourth Amendment’s
usual standards to “protect against gross abuses,”
New York v. P.J. Video, Inc., 475 U.S. 868, 874 (1986)
(quoting Heller v. New York, 413 U.S. 483, 492–93
(1973)), on the theory that applying those standards
with “scrupulous exactitude” will deny officers the
discretion to “rummage at large” or “deter normal
editorial and publication decisions,” Zurcher, 436 U.S.
at 564–66 (citation omitted).
In some contexts, the Court has gone further,
requiring that searches that intrude more heavyhandedly on First Amendment interests satisfy even
stricter standards. As Justice Gorsuch has observed,
“the First Amendment operates independently of the
Fourth and provides different protections,” Nieves v.
Bartlett, 587 U.S. 391, 414 (2019) (italics in original)
(Gorsuch, J., concurring in part and dissenting in
part), and so it is unsurprising that the typical
application of Fourth Amendment standards will not
always or fully safeguard First Amendment freedoms.
In United States v. Ramsey, for instance, even though
the Court concluded that the Fourth Amendment
permitted warrantless searches of mail at the border,
the Court reserved the separate question of whether
such searches would “impermissibly chill[] the
exercise of free speech” if not for a statutory
reasonable-suspicion requirement and a ban on
reading any correspondence contained therein. 431
U.S. 606, 624 (1977). And to similar effect, the Court
has held that other warrant exceptions—the exigency
exception, for instance—must yield to First
Amendment interests where, say, pursuing the
22
seizure of books or films absent a warrant “would
effectively constitute a ‘prior restraint.’” P.J. Video,
475 U.S. at 873 (citing Roaden v. Kentucky, 413 U.S.
496 (1973)).
The First and Fourth Amendments thus work
together to ensure that broad surveillance authority
does not abridge the freedoms of the press, speech,
and association.
B. Geofence
warrants
fail
a
straightforward—let
alone
scrupulous—application of the Fourth
Amendment’s requirements.
Geofence warrants enable searches that burden
First Amendment interests and must therefore meet
“the most scrupulous exactitude,” including in
“describ[ing] the things to be seized.” Stanford, 379
U.S. at 485 (citation omitted). Whether a description
is sufficiently specific or “too generalized to pass
constitutional muster” will depend on the
circumstances as well as the item seized. Id. at 48586. As described above, the circumstances here
include the obvious risk that a geofence warrant will
reveal and burden, intentionally or not, sensitive First
Amendment-protected activities and associations.
See supra, Part I. The power to expose any individual
present at a newsroom, a political rally, or a church
requires a level of particularity and precision that
geofence warrants like the one obtained here cannot
provide.
The Court’s precedents on modern locationtracking technologies reflect acute attention to the
23
capacity for these “innovations in surveillance tools”
to invade individual privacy and chill the exercise of
constitutional rights. Carpenter, 585 U.S. at 305; see
also U.S. Dist. Ct., 407 U.S. at 315. In reaffirming its
“special solicitude for location information,” the Court
in Carpenter stressed the “deeply revealing nature”
and “retrospective quality” of location data that
“provides an intimate window” into “familial, political,
professional, religious, and sexual associations.” 585
U.S at 311, 312, 314, 320 (citation omitted). Phone
location data, in particular, implicates these
overlapping Fourth and First Amendment concerns
because a phone “faithfully follows its owner beyond
public thoroughfares and into private residences,
doctor’s offices, political headquarters, and other
potentially revealing locales.” Id. at 311; see also
Kyllo, 533 U.S. at 40 (describing the “‘significant’
compromise of . . . privacy” that occurs when
surveillance reaches inside a person’s home).
Geofence searches pose an even “greater
danger to a free people” than the searches at issue in
Carpenter and Jones. Di Re, 332 U.S. at 595. Unlike
cell-site location information or GPS tracking of a
vehicle, the location data obtained through a geofence
search does not merely “provide[] an intimate
window” into the life of a single, specific suspect—it
reveals the movements, activities, and associations of
every person who happens to have been present near
the site and around the time of a suspected crime.
Carpenter, 585 U.S. at 311; see Jones, 565 U.S. 400.
Ready access to this kind of information would make
the work of painstaking stakeouts unnecessary: With
the location histories of millions within reach, “police
need not even know in advance whether they want to
24
follow a particular individual, or when. Whoever the
suspect turns out to be, he has effectively been tailed
every moment of every day[.]” Carpenter, 585 U.S. at
312. As a result, geofence searches dissolve the
traditional “practical” checks on improper monitoring
of the public and the press. Jones, 565 U.S. at 429
(Alito, J., concurring). Indeed, the general and
indiscriminate potential of geofence searches
resembles the reviled rummaging that inspired the
Fourth Amendment, supercharged for the digital age.
See Riley, 573 U.S. at 403.
The use of this power offends a reasonable
expectation of privacy, but geofence warrants like the
one here do not provide the particularity and precision
necessary to constrain it. They allow the government
to obtain the location data of any individual based on
happenstance—because they happened to be in the
vicinity of a suspected crime—with no consideration
for whether they are engaged in constitutionally
protected activity or association. In Ybarra v. Illinois,
the Court foreclosed this result, making clear that “a
person’s mere propinquity to others independently
suspected of criminal activity does not, without more,
give rise to probable cause to search that person.” 444
U.S. 85, 91 (1979). Just as probable cause to believe
that the bartender of the Aurora Tap Tavern, where
the search in Ybarra took place, was selling heroin did
not mean the police could search the pockets of every
patron present, see id., probable cause to believe that
someone was carrying a phone while committing a
bank robbery does not license a search of every
incidental passerby.
Were it otherwise—if the
government were required to show probable cause
only to believe that the dataset to be pulled would
25
contain the suspected criminal’s location somewhere
in its sweep—there would be no limit on the
permissible breadth of geofence searches. An index of
the entire neighborhood, or for that matter the entire
city, would be even more likely to catch the suspect in
its net. That result is untenable, and upholding this
warrant would authorize a digital-age version of the
same search that the Court held unconstitutional in
Ybarra.
***
The technology at issue in this case poses
intolerable threats to First Amendment-protected
activities and associations. Geofence searches enable
the tracking of people meeting in newspaper offices,
marching in protests, and attending houses of worship
with hardly a grain of individualized suspicion. This
Court should reaffirm that particularized warrants,
supported by individualized probable cause, play an
essential role in protecting First Amendment rights
from unjustified surveillance. “No less a standard
could be faithful to First Amendment freedoms.”
Stanford, 379 U.S. at 485.
CONCLUSION
For the foregoing reasons, the Reporters
Committee, Knight First Amendment Institute at
Columbia University, and FIRE respectfully urge the
Court to recognize the First Amendment interests at
stake in holding that the geofence warrant here
violated the Fourth Amendment.
Respectfully submitted,
26
Bruce D. Brown
Counsel of Record
Lisa Zycherman
Gabriel Rottman
Mara Gassmann
Grayson Clary
REPORTERS COMMITTEE FOR
FREEDOM OF THE PRESS
1156 15th St. NW,
Suite 1020
Washington, D.C. 20005
bruce.brown@rcfp.org
(202) 795-9300
Nicola Morrow
Jake Karr
Alex Abdo
KNIGHT FIRST AMENDMENT
INSTITUTE AT COLUMBIA
UNIVERSITY
475 Riverside Dr.,
Suite 302
New York, N.Y. 10115
nicola.morrow@knightcolumbia.org
(646) 745-8500
Counsel for Amici Curiae
March 2, 2026
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.