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Law School Case Brief

Samson v. California - 547 U.S. 843, 126 S. Ct. 2193 (2006)


The Fourth Amendment does not render states powerless to address recidivism concerns effectively. California's ability to conduct suspicionless searches of parolees serves its interest in reducing recidivism in a manner that aids, rather than hinders, the reintegration of parolees into productive society.


Pursuant to a California statute, which requires every state prisoner who was eligible for release on parole to agree in writing to be subject to search or seizure by a parole officer or other peace officer, with or without a search warrant and with or without cause, a police officer, solely on the basis of a former inmate's parolee status, searched the parolee and found methamphetamine. A state trial court denied Samson's, the parolee's, motion to suppress the methamphetamine evidence, convicted Samson of possession of methamphetamine, and sentenced him to seven years' imprisonment. On appeal, the California Court of Appeal affirmed the trial court’s judgment and held that the suspicionless searches of parolees were lawful under state law. The appellate court further held that the search in question was reasonable under the Federal Constitution's Fourth Amendment. The United States Supreme Court granted Samson's petition for certiorari review.


Did the suspicionless search of a parolee violate the Fourth Amendment? 




The U.S. Supreme Court held that the suspicionless search was a reasonable condition of parole that advanced state interests; moreover, parole conditions severely diminished the inmate's expectation of privacy while on parole. According to the Court, the State of California had substantial legitimate interests in reducing recidivism and thereby promoting reintegration and positive citizenship, and requiring individualized suspicion to support the search of a parolee would undermine those interests. Further, the constitutional requirement that the search be reasonable did not preclude the suspicionless search, and the parolee's limited privacy rights were protected by the prohibition of searches that are arbitrary, capricious, or harassing.

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