utility records reveal only the total amount of electricity a person is using in his home on a periodic basis and the amount being paid for those services. It does not divulge personal details — whether or when the person is watching television, talking on the telephone, or using any particular appliance. Thus, one could easily conclude that a person has a far greater expectation of privacy in his bank records than his utility records. Significantly, no state court has interpreted its own constitution to mandate that the police first obtain a warrant to obtain electric utility records. The state courts that have considered the issue have rejected the notion that there is a legitimate expectation of privacy in such records. See Samson v. State, 919 P.2d 171, 173 (Alaska Ct.App.1996) (<HOLDING>); People v. Stanley, 72 Cal.App.4th 1547, 86
holding that there is no reasonable expectation of privacy in utility records under either state or federal constitution holding no reasonable expectation of privacy in medical records because of statutory exception to physicianpatient privilege in homicide trials holding that a bank customer did not have a reasonable expectation of privacy in records maintained by the bank holding that no reasonable expectation of privacy in utility records exists under alaska constitution holding that prisoners have no reasonable expectation of privacy in their prison cells