The use of smart meters presents the recurring conflict between law enforcement's need to effectively investigate and combat crime and our desire for privacy while in our homes. With smart meters, police will have access to data that might be used to track residents' daily lives and routines while in their homes, including their eating, sleeping, and showering habits, what appliances they use and when, and whether they prefer the television to the treadmill, among a host of other details. Though a potential boon to police, access to this data is not limitless. The Fourth Amendment, which establishes the constitutional parameters for government investigations, may restrict access to smart meter data or establish rules by which it can be obtained. The Fourth Amendment ensures that the