The Ninth Circuit overruled cases to the extent they hold there is no constitutional difference between probationers and parolees for Fourth Amendment purposes. The court overruled a number of cases with respect to their holdings there is no “constitutional difference between probation and parole for purposes of the Fourth Amendment” because they conflict with the Supreme Court’s holding in Samson v. California (2006) 547 U.S. 843 (parolees have fewer expectations of privacy than probationers).