State and federal courts have long since wrestled with whether and how to apply the Katz test to advancing technology. For example, the U.S. Supreme Court in Katz determined that when the suspect entered the phone booth and shut the door, he had a reasonable expectation of privacy in his being there. Thus, the police conducted an unreasonable search by using a listening and recording device without getting a warrant. Similarly, in Kyllo v. United States, the Court decided that a suspect had a reasonable expectation of privacy in his home when the police, suspecting him of growing marijuana, used a thermal imaging device without a warrant to detect the heat emanating from it. In contrast, when the Court was asked in United States v. Ciraolo to decide whether a suspect had a reasonable expec