''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 turn on question ...

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, supervised release, or being on paper, is a form of early release of a prisoner, prison inmate where the prisoner agrees to abide by behavioral conditions, including checking-in with their designated ...

es are lawful under California law and that the search in this case was reasonable under the Fourth Amendment to the

United States Constitution The Constitution of the United States is the Supremacy Clause, supreme law of the United States, United States of America. It superseded the Articles of Confederation, the nation's first constitution, on March 4, 1789. Originally includi ...

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 In United States constitutional law, reasonable 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 U.S. Constitution. It is related to, ...

that a suspicionless search by a law enforcement officer would not offend the Fourth Amendment."

Background

Police search

On the afternoon of September 6, 2002,

San Bruno, California San 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, California, South San Francisco and Millbrae, Cali ...

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 had been

paroled Parole, also known as provisional release, supervised release, or being on paper, is a form of early release of a prison inmate where the prisoner agrees to abide by behavioral conditions, including checking-in with their designated parole of ...

and had heard from other officers that Samson "might have a parolee at large warrant". Rohleder parked his police vehicle, approached Samson, and "made contact" with him. When Rohleder asked Samson whether 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 because of his status as a parolee. One of Samson's conditions of parole was agreement 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 The Penal Code of California forms the basis for the application of most criminal law, criminal procedure, penal institutions, and the execution of sentences, among other things, in the United States, American state of California. It was origin ...

Section 3067(a). Rohleder found a cigarette box in Samson's left breast pocket that held a plastic bag containing

methamphetamine Methamphetamine (contracted from ) is a potent central nervous system (CNS) stimulant that is mainly used as a recreational drug use, recreational or Performance-enhancing substance, performance-enhancing drug and less commonly as a secon ...

. Samson was arrested and later charged with violating

California Health and Safety Code The California Health and Safety Code is the codification of general statutory law covering the subject areas of health and safety in the state of California. It is one of the 29 California Codes and was originally signed into law by the Governor ...

Ann. §11377(a).

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 §3067(a) authorized the search and that it 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 that the trial court improperly admitted the evidence from the search. The

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 "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 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