Naperville Smart Meter Awareness v. City of Naperville

Federal 7th Circuit Court
Civil Court
Fourth Amendment
Citation
Case Number: 
No. 16-3766
Decision Date: 
August 16, 2018
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiff’s complaint alleging that defendant-City violated 4th Amendment rights of plaintiff’s members by using “smart meters” to record power usage in members’ homes at 15-minute intervals, which according to plaintiff, constituted unreasonable search, because data recorded by said meters could reveal intimate personal details of members’ actions while in their homes. While collection of such data qualified as search for purposes of 4th Amendment, since said data could reveal when people are home and when certain appliances are being used, Ct. of Appeals found that said searches are reasonable, since: (1) instant data collection was not performed as part of criminal investigation; and (2) instant intrusion on members’ 4th Amendment interests was minimal, while governmental interests in using said meters were significant, where meters represented modernization of energy grid that could be used to restore electrical service more quickly and to reduce labor costs.