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Kyllo v. United States
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The facts
An agent came to suspect marijuana was being grown in the Defendant's home based on an informant tip and utility records suggesting above-average electricity use consistent with high-intensity grow lamps. At 3:20 a.m. on January 16, 1992, agents used an Agema Thermovision 210 thermal imager from a public street. The scan showed that the Defendant's garage roof and side wall were significantly warmer than other parts of the triplex — heat consistent with high-intensity lamps. Execution of the search warrant revealed more than 100 marijuana plants growing under high-intensity lamps, along with related equipment.
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