A parole search of a parolees home by officers who expected to find no evidence of a crime on the premises but conducted a search because they thought it would pressure the parolee into talking about his role in an unsolved robbery occurring two years earlier, was unreasonable under the Fourth Amendment. The Ninth Circuit took as its starting point the decision in United States v. Knights (2001) 534 U.S. 112. The court balanced the diminished privacy interests of a parolee against the governments interest in the search to determine if it was objectively reasonable. The court rejected validating the search on the “special needs” of the parole system and concluded that a suspicionless search for law enforcement purposes has never been constitutionally authorized.
Case Summaries