Quoting Alex Mandel (tech_...@wildintellect.com):

> Good Call, I did look a little at finding a drive case that was both
> eSata and usb. The drive case was the cheapest part by far but esata/usb
> isn't so common. I'm not sure if the board in between would still be an
> issue. If I happen to come upon a good deal on such a case I might try
> it. Anyone have an external eSata they could try to get SMART data on?

All libata drivers support SMART -- which is what one would expect,
given that libata leverages the kernel's SCSI layers.
https://ata.wiki.kernel.org/index.php/Libata_Feature_Table
(The particular SATA interface, internal vs. eSATA, is not an issue.)

For SATA drivers that aren't part of Jeff Garzik's libata collection,
you would have to check the particulars of those drivers.  But I expect
most people would use libata drivers.

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