Law School Case Brief
United States v. Knights - 534 U.S. 112, 122 S. Ct. 587 (2001)
When an officer has reasonable suspicion that a probationer subject to a search condition is engaged in criminal activity, there is enough likelihood that criminal conduct is occurring that an intrusion on the probationer's significantly diminished privacy interests is reasonable.
Defendant Michael James Knights was sentenced to probation after he was convicted of a drug offence. The sentencing order included the condition that Knights submit to search at anytime, with or without a search or arrest warrant or reasonable cause, by any probation or law enforcement officer. Subsequently, a sheriff's detective, with reasonable suspicion, searched Knights's apartment. Based in part on items recovered, a federal grand jury indicted Knights for conspiracy to commit arson, for possession of an unregistered destructive device, and for being a felon in possession of ammunition. Knights moved to suppress the evidence found in his apartment during a search conducted pursuant to the probation condition consenting to searches. In granting Knights's motion to suppress, the District Court held that, although the detective had "reasonable suspicion" to believe that Knights was involved with incendiary materials, the search was for "investigatory" rather than "probationary" purposes. The United States Court of Appeals for the Ninth Circuit affirmed, and the United States Supreme Court granted the government's petition for writ of certiorari.
Is a warrantless search of a probationer's apartment, supported by reasonable suspicion and authorized by condition of probation, reasonable within meaning of Federal Constitution's Fourth Amendment?
The oUnited States Supreme Curt found that the search was reasonable under the general Fourth Amendment approach of examining the totality of the circumstances, with the probation search condition being a salient circumstance. The Court found that defendant's status as a probationer subject to a search condition diminished his reasonable expectation of privacy. Although the Fourth Amendment ordinarily required probable cause, a lesser degree satisfied the United States Constitution when the balance of governmental and private interests made such a standard reasonable. The court found that when an officer had reasonable suspicion that a probationer subject to a search condition was engaged in criminal activity, there was enough likelihood that criminal conduct was occurring that an intrusion on the probationer's significantly diminished privacy interests was reasonable. The district court found, and defendant conceded, that the search was supported by reasonable suspicion. Thus, the court held that the warrantless search of defendant, supported by reasonable suspicion and authorized by a condition of probation, was reasonable within the meaning of the Fourth Amendment.
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