Kyllo v. United States, 533 U.S. 27 (2001)

Facts

Agents suspected that Kyllo was growing marijuana inside his home and conducted a thermal imaging scan of the exterior of the home.  This scan showed an unusual amount of heat radiating from a portion of the home, typically related to high-intensity lamps.  With the scan, along utility bills, and tips, a search warrant was issued and marijuana plants discovered in the home.

Procedural History

The District Court refused to suppress the evidence and Kyllo entered a conditional guilty plea.  The Court of Appeals affirmed, finding Kyllo had no expectation of privacy because he made no attempt to conceal the heat.

Issue(s)

Is the use of thermal-imaging devices aimed at a private home from a public street to detect relative amounts of heat a search within the meaning of the Fourth Amendment?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that in the case of the search of the interior of homes, there is already a criterion of the minimal expectation of privacy that exists, and that is acknowledged to be reasonable.  We think that obtaining by sense-enhancing technology any information regarding the interior of the home that could not otherwise been obtained without physical intrusion into a constitutionally protected area constitutes a search.

Judgment/Outcome

The Court reversed and remanded the judgment of the Court of Appeals.