Brief Fact Summary. Respondent was living under specific probationary restraints that permitted a search of his person with or without warrant by law officers. Respondent became a suspect in a vandalism spree. After observation by a detective, respondent was searched and arrested.
Synopsis of Rule of Law. The balance of protecting citizens and observing probationers “requires no more than reasonable suspicion [under the Fourth Amendment] to conduct a search of this probationer’s house.”
Issue. “[W]hether the Fourth Amendment limits searches pursuant to this probation condition to those with a ‘probationary’ purpose.”
Held. No. The respondent’s argument, that the “probationary” purpose limitation “follows from our decision in Griffin v. Wisconsin,” . . . which was a “special needs” system, in which, under Wisconsin law, “applied to all Wisconsin probationers.” In other words, the respondent argued, any search must be a “search conducted by a probation officer monitoring whether the probationer is complying with probation restrictions” to comply with the Fourth Amendment. The Supreme Court dismissed this, instead focusing on a “reasonableness”, and that a State’s “interest in apprehending violators of the criminal law, thereby protecting potential victims of criminal enterprise, may therefore justifiably focus on probationers in a way that it does not on the ordinary citizen.”
In Knights, the Supreme Court held that a warrantless search supported by reasonable suspicion and authorized by a condition of probation, was reasonable within the meaning of the Fourth Amendment.View Full Point of Law