Case Explained: UNITED STATES OF AMERICA v. ERIC KENDRICK

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-09

The Seventh Circuit affirmed the district court’s denial of Eric Kendrick’s motion to suppress evidence obtained via a pole camera installed on a public utility pole across from his leased auto-repair shop. The court held that the warrantless surveillance did not violate the Fourth Amendment because Kendrick lacked both a subjective and an objectively reasonable expectation of privacy in the activities captured by the camera. Applying the two-part test from *Katz v. United States*, the court found that Kendrick failed to manifest a sufficient subjective expectation of privacy, as the property’s fence contained a thirty-foot gap through which vehicles and individuals entered and exited, rendering the observed activities visible to ground-level passersby. Furthermore, the court determined that society would not recognize such an expectation as reasonable given the commercial nature of the property, which affords less Fourth Amendment protection than a residence. Relying on *United States v. House*, *United States v. Tuggle*, and *California v. Ciraolo*, the court concluded that the surveillance utilized common technology from a public vantage point where officers were lawfully entitled to be, capturing events that were plainly visible to the public. Consequently, the judgment of conviction is affirmed, and Kendrick’s 140-month sentence and five years of supervised release stand.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.