Samson v. California
Encyclopedia
Samson v. California, 547 U.S. 843
(2006), was a case in which the Supreme Court of the United States
affirmed the decision of the California Court of Appeal
; which held that suspicionless searches of parole
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. 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
that a suspicionless search by a law enforcement officer would not offend the Fourth Amendment."
Police Officer Alex Rohleder observed "two adults and a little baby walking down the street." One of the adults, whom Officer Rohleder recognized "from a prior contact" was the defendant in the case, Donald Curtis Samson. Rohleder knew that defendant 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 to which the Defendant replied that he did not have a warrant and "was in good standing with his parole agent." Rohleder confirmed over his police radio that defendant 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).
Officer Rohleder found a cigarette box in Samson's left breast pocket which held a plastic baggie that contained methamphetamine
.
Samson was arrested and later charged with violating California Health and Safety Code
Ann. §11377(a), for possessing the methamphetamine.
Samson appealed his conviction on the grounds the trial court improperly admitted the evidence from the search. The California Court of Appeal
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:
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
affirmed the decision of the California Court of Appeal
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 into six appellate districts...
; which held that suspicionless searches of parole
Parole
Parole may have different meanings depending on the field and judiciary system. All of the meanings originated from the French parole . Following its use in late-resurrected Anglo-French chivalric practice, the term became associated with the release of prisoners based on prisoners giving their...
es are lawful under California law and that the search in this case was reasonable under the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
to the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
because it was not arbitrary, capricious, or harassing. 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
In United States constitutional law the 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...
that a suspicionless search by a law enforcement officer would not offend the Fourth Amendment."
Police search
In the afternoon of September 6, 2002, San BrunoSan Bruno, California
San Bruno is a city in San Mateo County, California, United States. The population was 41,114 at the 2010 census.The city is adjacent to San Francisco International Airport and Golden Gate National Cemetery.-Geography:San Bruno is located at...
Police Officer Alex Rohleder observed "two adults and a little baby walking down the street." One of the adults, whom Officer Rohleder recognized "from a prior contact" was the defendant in the case, Donald Curtis Samson. Rohleder knew that defendant 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 to which the Defendant replied that he did not have a warrant and "was in good standing with his parole agent." Rohleder confirmed over his police radio that defendant 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
California Penal Code
The Penal Code of California forms the basis for the application of criminal law in the American state of California. It was originally enacted in 1872 as one of the original four California Codes, and has been substantially amended and revised since then....
Section 3067.(a).
Officer Rohleder found a cigarette box in Samson's left breast pocket which held a plastic baggie that contained methamphetamine
Methamphetamine
Methamphetamine is a psychostimulant of the phenethylamine and amphetamine class of psychoactive drugs...
.
Samson was arrested and later charged with violating California Health and Safety Code
California Health and Safety Code
California Law consists of 29 codes, covering various subject areas, the State Constitution and Statutes. The California Health and Safety Code is the code covering the subject areas of health and safety.-External links:...
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 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
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 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 " '[s]uch 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.