United States v. Knights

PETITIONER: United States
RESPONDENT: Knights
LOCATION: York County Court

DOCKET NO.: 00-1260
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 534 US 112 (2001)
ARGUED: Nov 06, 2001
DECIDED: Dec 10, 2001

ADVOCATES:
Hilary A. Fox - Oakland, California, argued the cause for the respondent
Malcolm L. Stewart - Argued the cause for the petitioner, on behalf of the Petitioner

Facts of the case

A California court sentenced Mark James Knights to probation for a drug offense. The probation order included the following condition: that Knights would "submit his...person, property, place of residence, vehicle, personal effects, to search at anytime, with or without a search warrant, warrant of arrest or reasonable cause by any probation officer or law enforcement officer." In the aftermath of arson at the site of a Pacific Gas and Electric (PGE) power transformer, a sheriff's detective, with reasonable suspicion, searched Knights's apartment. Based in part on items recovered, including a PGE padlock, 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. 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 Court of Appeals affirmed.

Question

Does a search pursuant to a common California probation condition, supported by reasonable suspicion, satisfy the Fourth Amendment?

Media for United States v. Knights

Audio Transcription for Oral Argument - November 06, 2001 in United States v. Knights

Audio Transcription for Opinion Announcement - December 10, 2001 in United States v. Knights

William H. Rehnquist:

I have the opinion of the Court to announce in No. 00-1260, United States against Knights.

A California Court sentenced respondent Mark James Knights to summary probation for a drug offense.

The probation order included the following condition that Knights would submit its person, property, place of residence, vehicle, personal effects, to search at anytime with or without a search warrant, warrant of arrest or reasonable cause by any probation officer or law enforcement officer.

Knights signed the probation officer which stated that he received a copy, understood it, and agreed to abide by it.

Just a few days after, he was placed on probation, a PG&E power transformer in California was set on fire causing an estimated million and half dollars in damage.

He and his friends, a man named Steven Simon have long been suspects in numerous acts of vandalism committed against PG&E property.

Several more events occurring after the arson increased the suspicion.

Finally, Detective Hancock decided to search Knights' apartment.

He was aware of Knights’ probation condition so he did not think a warrant was necessary.

The search has revealed a detonation card, ammunition, liquid chemicals, instruction manuals on chemistry and electrical circuitry, bold cutters, telephone pole-climbing spurs, drug paraphernalia and a brass padlocks stamped PG&E.

He was arrested and the Federal Grand Jury indicted him for conspiracy to commit arson, possession of unregistered destructive device and being a felon in possession of ammunition.

He moved to suppress the evidence obtained during the search of his apartment.

The District Court held that Detective Hancock had reasonable suspicion to believe that Knights was involved in the arson but it granted the motion to suppress because of some cases from the Ninth Circuit Court of Appeals that siad a stop like this have to be in probationary rather than investigatory in order to be done without a warrant and without probable cause.

The Court of Appeals affirms, and in an opinion filed with the Clerk today, we reversed.

The lower courts agreed that reasonable suspicion under our cases existed for this search.

That is a degree of suspicion less than probable cause but for what we call a Terry Stop, but the court of Appeals thought that since it was for law enforcement purposes not rehabilitation purposes, it was invalid under the Fourth Amendment, but while one of the interests of the government in granting probation is to rehabilitate the probationer.

Another equally important interest is to protect the community from criminal enterprise.

We have observed and statistics support the observation that probationers are more likely to engage in criminal conduct and ordinary citizens.

This interest of the government together with Knights decreased expectation of privacy by reason of his probation condition justified the search here.

The decision is unanimous.

Justice Souter has filed a concurring opinion.