Monday, November 4, 2013

Samson v. California case brief

Samson v. California case brief summary
126 S. Ct. 2193 (2006)

Petitioner prison inmate was convicted of possession of drugs but asserted that Cal. Penal Code § 3067(a) (2000) unconstitutionally allowed the arresting officer to search the inmate without suspicion of criminal activity based solely on the inmate's status as a parolee. Upon the grant of a writ of certiorari, the inmate appealed the judgment of the California Court of Appeal, First Appellate District, which upheld the search.

The officer recognized the inmate as a parolee and, even though the officer did not suspect the inmate of any criminal activity, the officer searched the inmate under the authority of § 3067(a) and discovered drugs in the inmate's possession. The inmate contended that the statutory provision for the suspicionless search based solely on the inmate's status as a parolee violated the inmate's constitutional right to be free of unreasonable searches.

The U.S. Supreme Court held, however, that the suspicionless search was a reasonable condition of parole which advanced state interests and parole conditions severely diminished the inmate's expectation of privacy while on parole.

  • The State of California had substantial legitimate interests in reducing recidivism and thereby promoting reintegration and positive citizenship, and requiring individualized suspicion to support the search of the inmate would undermine those interests. 
  • Further, the constitutional requirement that the search be reasonable did not preclude the suspicionless search, and the inmate's limited privacy rights were protected by the prohibition of searches which were arbitrary, capricious, or harassing.


The judgment upholding the suspicionless search of the inmate was affirmed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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