{"id":44366,"date":"2020-06-30T10:57:28","date_gmt":"2020-06-30T15:57:28","guid":{"rendered":"http:\/\/fourthamendment.com\/?p=44366"},"modified":"2020-06-30T10:58:53","modified_gmt":"2020-06-30T15:58:53","slug":"m-d-fla-seven-weeks-of-pole-camera-surveillance-of-front-of-house-was-reasonable","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=44366","title":{"rendered":"M.D.Fla.: Seven weeks of pole camera surveillance of front of house was reasonable"},"content":{"rendered":"\n<p>A pole camera observing the front of defendant\u2019s house for seven weeks was reasonable. United States v. Bronner, 2020 U.S. Dist. LEXIS 113076 (M.D. Fla. May 18, 2020):<\/p>\n\n\n\n<!--more-->\n\n\n\n<blockquote class=\"wp-block-quote is-layout-flow wp-block-quote-is-layout-flow\"><p>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 May 28, 2019) (unpublished) (finding that the defendant had no reasonable expectation of privacy in public area captured by pole camera installed outside a warehouse), report and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 Aug. 13, 2019) (unpublished); United States v. Gbenedio, No. 1:17-CR-430-TWT-JSA, 2019 WL 2177943, at *2 (N.D. Ga. Mar. 29, 2019) (unpublished) (finding no Fourth Amendment violation by &#8220;the use of a pole camera installed on public property, or property unaffiliated with [the d]efendant, to view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&#8221;), 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 May 17, 2019) (unpublished); United States v. Edmonds, No. 2:18-CR-00225-01, 2020 WL 573272, at *3 (S.D.W. Va. Feb. 5, 2020) (unpublished) (finding no Fourth Amendment violation by warrantless installation of pole camera that captured &#8220;footage of vehicles coming and going from the residences\u2014something that can be observed by any neighbor, passer-by, or officer physically surveilling the area&#8221; (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&#8217;s house that recorded the exterior of the defendant&#8217;s residence).<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"<p>A pole camera observing the front of defendant\u2019s house for seven weeks was reasonable. United States v. Bronner, 2020 U.S. Dist. LEXIS 113076 (M.D. Fla. May 18, 2020):<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[92],"tags":[],"class_list":["post-44366","post","type-post","status-publish","format-standard","hentry","category-pole-cameras"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/44366","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=44366"}],"version-history":[{"count":2,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/44366\/revisions"}],"predecessor-version":[{"id":44368,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/44366\/revisions\/44368"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=44366"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=44366"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=44366"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}