United States v. Knights
534 U.S. 112 (2001)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A warrantless search of a probationer's residence, authorized by a condition of their probation and supported by reasonable suspicion, is permissible under the Fourth Amendment's reasonableness standard.
Facts:
- Mark James Knights was sentenced to summary probation for a drug offense.
- As a condition of his probation, Knights agreed in writing to submit his person, property, and residence to search at any time by any probation or law enforcement officer, with or without a search warrant or reasonable cause.
- Three days later, a Pacific Gas & Electric (PG&E) power transformer was pried open and set on fire, the latest in a series of over 30 acts of vandalism against PG&E.
- Suspicion had long focused on Knights and his friend, Steven Simoneau, for these acts, which began after PG&E discontinued Knights' electrical service for nonpayment.
- A detective surveilling Knights' apartment observed Simoneau leave with three cylindrical items, heard splashes in a nearby river, and saw Simoneau return without the items.
- Shortly after, the detective observed a Molotov cocktail, explosive materials, a gasoline can, and brass padlocks matching those from the PG&E crime scene inside Simoneau's truck, which was parked near Knights' residence.
Procedural Posture:
- Knights was indicted by a federal grand jury for conspiracy to commit arson and other related charges.
- In the U.S. District Court, Knights filed a motion to suppress the evidence found during the search of his apartment.
- The District Court found that the detective had reasonable suspicion for the search but granted the motion to suppress, ruling the search's purpose was 'investigatory' rather than 'probationary'.
- The United States, as the prosecuting party, appealed this decision to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit affirmed the District Court's decision to suppress the evidence.
- The United States then petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a warrantless search of a probationer's residence, conducted by a law enforcement officer for an investigatory purpose and supported by reasonable suspicion, violate the Fourth Amendment when the probationer has agreed to a search condition as part of their probation?
Opinions:
Majority - Chief Justice Rehnquist
No. The warrantless search of a probationer's home, supported by reasonable suspicion and authorized by a condition of probation, is reasonable and does not violate the Fourth Amendment. The court evaluates such searches under a general Fourth Amendment reasonableness analysis by examining the totality of the circumstances. This involves balancing the intrusion upon an individual's privacy against the promotion of legitimate governmental interests. Knights' status as a probationer and his unambiguous acceptance of the search condition significantly diminished his reasonable expectation of privacy. On the other side of the balance, the state has a legitimate interest in preventing future criminal activity and promoting rehabilitation, and probationers are statistically more likely to engage in crime. This balance of interests warrants a lesser standard than probable cause, making a search based on reasonable suspicion constitutionally sufficient. The Court rejected the distinction between 'probationary' and 'investigatory' purposes for the search, holding that an officer's subjective motivation is irrelevant under this reasonableness analysis.
Concurring - Justice Souter
Justice Souter concurred, agreeing with the judgment but writing separately to express a point of caution. He noted that the Court's holding obviates the need to consider the subjective intent of the investigating officers. He would reserve for a future case the question of whether the rule from Whren v. United States—that subjective intentions are irrelevant in ordinary, probable-cause Fourth Amendment analysis—should be extended to searches that are based only on the lower standard of reasonable suspicion.
Analysis:
This decision clarifies that the constitutionality of probation searches is not limited to the 'special needs' of the probation system, but can be justified under a broader Fourth Amendment reasonableness balancing test. It empowers law enforcement by allowing searches of probationers for general investigatory purposes, not just to monitor compliance with probation terms. By establishing reasonable suspicion as the sufficient standard in this context, the Court lowered the bar from the probable cause typically required for home searches, reflecting the diminished privacy rights of individuals on probation.
Unlock the full brief for United States v. Knights