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It is well established that the Fourth Amendment protects a privacy interest in commercial premises. See Oliver v. United States, 466 U.S. at 466 U. S. 178, n. 8 (the protection of privacy interests in business premises is 'based on societal expectations that have deep roots in the history of the Amendment'). See also Marshall v. Barlow's, Inc., 436 U. S. 307, 436 U. S. 312 (1978) (the historical foundation of the Fourth Amendment reveals that 'it is untenable that the ban on warrantless searches was not intended to shield places of business as well as of residence'); See v. City of Seattle, 387 U. S. 541, 387 U. S. 543 (1967) ('The businessman, like the occupant of a residence, has a constitutional right to go about his business free from unreasonable official entries upon his private commercial property'). 


Property used for commercial purposes is treated differently for Fourth Amendment purposes from residential property. “An expectation of privacy in commercial premises, however, is different from, and indeed less than, a similar expectation in an individual's home.” New York v. Burger, 482 U.S. 691, 700 (1987).


Since Katz v. United States, 389 ...

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