Supreme Court Case on Probation Warrantless Search

In United States v. Knights (2001) 534 U.S. 112 151 L. Ed. 2d 497, 122 S. Ct. 587, the appellant and a friend were suspected of committing arson and vandalizing Pacific Gas & Electric (PG&E) property. A detective saw appellant's friend leaving appellant's apartment around 3:00 a.m. carrying three cylinders that appeared to be pipe bombs. When he looked in the back of the friend's truck, the detective saw PG&E padlocks and various explosive materials. Based on his observations, the officer searched appellant's apartment pursuant to a probation search condition. (Knights, supra, 534 U.S. at pp. 114-115 151 L. Ed. 2d at pp. 502-503.) The Ninth Circuit Court of Appeals found the search was invalid because it was motivated by "'investigatory'" purposes rather than "'probationary'" purposes. (Id. at p. 116 151 L. Ed. 2d at p. 503.) The United States Supreme Court rejected this distinction, noting that nothing in the appellant's search condition suggested it was confined to searches bearing upon probationary status. (Ibid.) Determining that probation searches need not be justified by probable cause, Knights held "the warrantless search of appellant's apartment, supported by reasonable suspicion and authorized by a condition of probation, was reasonable within the meaning of the Fourth Amendment." (Id. at pp. 121-122, 151 L. Ed. 2d at pp. 506, 507.) Although Knights found the search was supported by reasonable suspicion and, therefore, passed constitutional muster, this does not lead ineluctably to the conclusion that reasonable suspicion is required in all cases. An opinion upholding a particular search does not necessarily hold unconstitutional any search that is not like it. (Knights, supra, 534 U.S. at pp. 117-118 151 L. Ed. 2d at p. 504.) Because the search in Knights was supported by a reasonable suspicion, the Supreme Court expressly declined to decide whether a probation search by a law enforcement officer without reasonable suspicion satisfies the reasonableness requirement of the Fourth Amendment. (Id. at p. 120 151 L. Ed. 2d at p. 505, fn. 6.)