Samson v. California

Facts of the Case

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.

Question

Did the Fourth Amendment prohibit police from conducting a warrantless search of a person who was subject to a parole search condition, where there was no suspicion of criminal wrongdoing and the sole reason for the search was because the person was on parole?

CONCLUSION

No. In a 6-to-3 decision authored by Justice Clarence Thomas, the Supreme Court held that Samson did not have an expectation of privacy that society would recognize as legitimate. Parole allows convicted criminals out of prison before their sentence is completed. An inmate who chooses to complete his sentence outside of direct physical custody, however, remains in the Department of Correction’s legal custody until the conclusion of his sentence, and therefore has significantly reduced privacy rights. In this case, Samson had also been required, as a condition of his parole, to sign an agreement that he would 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. This written consent to suspicionless searches, along with his already reduced privacy interests as a parolee, combined to make the search constitutional. Justices Stevens, Souter and Breyer dissented, arguing that parolees have an expectation of privacy greater than that of prisoners, which was violated by the search at issue in this case.Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales , a nonpartisan Oyez resource.

Case Information

  • Citation: 547 US 843 (2006)
  • Granted: Sep 27, 2005
  • Argued: Feb 22, 2006
  • Decided Jun 19, 2006