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In an age in which the government can see through walls with "night vision,"' electromagnetic detection devices,2 and other advanced technology,3 privacy rights are once again under attack. Police use thermal imaging devices to detect the "heat signatures" of our bodies and other sources in our homes; yet, a number of federal circuit courts have held that such intrusion is not a Fourth Amendment "search," and thus does not require a warrant:4 the intrusion takes place without case-by-case judicial review, and

"Intimate Details": A Troubling New Fourth Amendment Standard for Government Surveillance Techniques