Chatrie was about Google’s personal location tracking feature in Android, not about carrier tower records.

Which is also irrelevant

There's nothing special about any particular technology at all. The question is whether people have an option to generate the data for a third party (Google, Flock, or cell tower operators) and then the sensitivity of that resulting data.

Carpenter is pretty simple: If you by virtue of existing in the modern world produce a bunch of super sensitive data that third parties now have, then those third parties aren't allowed to just give the government that data.