A pole camera observing the front of defendant’s house for seven weeks was reasonable. United States v. Bronner, 2020 U.S. Dist. LEXIS 113076 (M.D. Fla. May 18, 2020):
In light of ever-evolving technology and recent Supreme Court Fourth Amendment jurisprudence (including Carpenter and Jones), some courts are re-examining whether pole cameras implicate the Fourth Amendment. As summarized above, some courts have found the Fourth Amendment is implicated; others, however, have found it is not. See, e.g., Report and Recommendation (Doc. No. 159), United States v. Ratliff, No. 3:18-cr-00206-J-25JRK (M.D. Fla. Oct. 16, 2019), adopted, Order (Doc. No 182), No. 3:18-cr-00206-J-25JRK (M.D. Fla. Jan. 15, 2020); United States v. Fanning, No. 1:18-CR-362-ATCMS, 2019 WL 6462830, at *3-4 (N.D. Ga. May 28, 2019) (unpublished) (finding that the defendant had no reasonable expectation of privacy in public area captured by pole camera installed outside a warehouse), report and recommendation adopted, No. 1:18-CR-0362-AT-1, 2019 WL 3812423 (N.D. Ga. Aug. 13, 2019) (unpublished); United States v. Gbenedio, No. 1:17-CR-430-TWT-JSA, 2019 WL 2177943, at *2 (N.D. Ga. Mar. 29, 2019) (unpublished) (finding no Fourth Amendment violation by “the use of a pole camera installed on public property, or property unaffiliated with [the d]efendant, to view the exterior of a commercial business in a publicly accessible strip mall”), report and recommendation adopted, No. 1:17-CR-430-TWT, 2019 WL 2173994 (N.D. Ga. May 17, 2019) (unpublished); United States v. Edmonds, No. 2:18-CR-00225-01, 2020 WL 573272, at *3 (S.D.W. Va. Feb. 5, 2020) (unpublished) (finding no Fourth Amendment violation by warrantless installation of pole camera that captured “footage of vehicles coming and going from the residences—something that can be observed by any neighbor, passer-by, or officer physically surveilling the area” (citation omitted)); United States v. Kelly, 385 F. Supp. 3d 721, 726-30 (E.D. Wis. 2019) (finding warrantless installation of camera outside a drug stash apartment did not implicate the Fourth Amendment); United States v. Kubasiak, No. 18-CR-120-PP, 2018 WL 4846761, at *3-8 (E.D. Wis. Oct. 5, 2018) (unpublished) (finding no implication of Fourth Amendment in fixed camera placed in a neighbor’s house that recorded the exterior of the defendant’s residence).