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''Samson v. California'', 547 U.S. 843 (2006), is a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case in which the Court affirmed the
California Court of Appeal The California Courts of Appeal are the state intermediate appellate courts in the U.S. state of California. The state is geographically divided along county lines into six appellate districts.
's ruling that suspicionless searches of
parole Parole (also known as provisional release or supervised release) is a form of early release of a prison inmate where the prisoner agrees to abide by certain behavioral conditions, including checking-in with their designated parole officers, or ...
es are lawful under California law and that the search in this case was reasonable under the Fourth Amendment to the United States Constitution because it was not arbitrary, capricious, or harassing.''The Supreme Court, 2005 Term — Leading Cases,''
120 Harv. L. Rev. 183 (2006). This case answered in the affirmative a variation of the question the Court left open in '' United States v. Knights'', 534 U.S. 112, 120 n.6 (2001), "whether a condition of release can so diminish or eliminate a released prisoner's reasonable
expectation of privacy Expectation of privacy is a legal test which is crucial in defining the scope of the applicability of the privacy protections of the Fourth Amendment to the United States Constitution. It is related to, but is not the same as, a ''right to privac ...
that a suspicionless search by a law enforcement officer would not offend the Fourth Amendment."


Background


Police search

In the afternoon of September 6, 2002,
San Bruno San Bruno (Spanish for " St. Bruno") is a city in San Mateo County, California, United States, incorporated in 1914. The population was 43,908 at the 2020 United States Census. The city is between South San Francisco and Millbrae, adjacent to ...
Police Officer Alex Rohleder observed "two adults and a little baby walking down the street." One of the adults, whom Rohleder recognized "from a prior contact" was the defendant in the case, Donald Curtis Samson. Rohleder knew that Samson was on parole and had heard from other officers that Samson "might have a parolee at large warrant." Rohleder then parked his police vehicle and approached Samson and "made contact" with him. When Rohleder asked Samson if he had a warrant, Samson replied that he did not and "was in good standing with his parole agent." Rohleder confirmed over his police radio that Samson was not subject to a parole warrant, but was on parole for a prior parole violation. Rohleder conducted a search of Samson due to his status as a parolee. One of Samson's conditions of parole stated that he had agreed to "search and seizure by a parole officer or other peace officer at any time of the night or day, with or without a search warrant or with or without cause." This condition is required by California Penal Code Section 3067.(a). Rohleder found a cigarette box in Samson's left breast pocket that held a plastic baggie containing methamphetamine. Samson was arrested and later charged with violating California Health and Safety Code Ann. §11377(a), for possessing the methamphetamine.


State court trial and appeal

At trial, Samson moved to suppress the methamphetamine evidence, which was denied by the trial court. The court found that Cal. Penal Code Ann. §3067(a) authorized the search and that the search was not "arbitrary or capricious." The jury convicted Samson and the trial court sentenced him to seven years in prison. Samson appealed his conviction on the grounds the trial court improperly admitted the evidence from the search. The
California Court of Appeal The California Courts of Appeal are the state intermediate appellate courts in the U.S. state of California. The state is geographically divided along county lines into six appellate districts.
affirmed the trial court's ruling, relying on ''People v. Reyes'', 19 Cal. 4th 743, 968 P. 2d 445 (1998), in which the court held that:
''suspicionless searches of parolees are lawful under California law; that " ' ch a search is reasonable within the meaning of the Fourth Amendment as long as it is not arbitrary, capricious or harassing' "; and that the search in this case was not arbitrary, capricious, or harassing.''


References


External links

* {{US4thAmendment, warrantexceptions, state=expanded United States Supreme Court cases United States Supreme Court cases of the Roberts Court United States Fourth Amendment case law 2006 in United States case law