Sunday, November 3, 2013

United States v. Knights

United States v. Knights case brief summary
534 U.S. 112 (2001)

Defendant moved to suppress evidence found in his apartment during a search conducted pursuant to a probation condition consenting to searches. The district court granted the motion on the ground that the search was for investigatory rather than probationary purposes. The United States Court of Appeals for the Ninth Circuit affirmed, and the court granted the government's petition for writ of certiorari.

  • The defendant (Knights) was sentenced to summary probation for a drug conviction. 
  • As a condition of probation, the defendant was ordered to allow any probation or law enforcement officer to search his person or property without a warrant or without reasonable cause. 
  • The defendant signed the order stating that he understood and agreed to the terms of probation. 
  • Later, a detective with the Napa County Sheriff’s Department began to suspect the defendant and Steven Simoneau of committing a series of acts of vandalism against Pacific Gas & Electric Company. 
  • After seeing suspicious materials in Simoneau’s truck parked in the defendant’s driveway, the detective decided to search his apartment. 
  • Because of the search provision in Knights’ probation order, the detective didn't believe he needed a warrant. 
  • The detective found bomb making materials and evidence of the PG&E vandalism and arrested the defendant. 
  • The defendant was indicted by a grand jury in federal court. 
  • The defendant then moved to suppress the evidence found during the search, and the district court granted the motion because the search was conducted for investigative instead of probationary purposes. 
  • The United States Court of Appeals for the Ninth Circuit Affirmed the ruling. 
  • The United States Supreme Court granted certiorari.


  • The court found that the search was reasonable under the general Fourth Amendment approach of examining the totality of the circumstances, with the probation search condition being a salient circumstance. 
  • The court found that defendant's status as a probationer subject to a search condition diminished his reasonable expectation of privacy. 
  • Although the Fourth Amendment ordinarily required probable cause, a lesser degree satisfied the United States Constitution when the balance of governmental and private interests made such a standard reasonable. 
  • The court found that when an officer had reasonable suspicion that a probationer subject to a search condition was engaged in criminal activity, there was enough likelihood that criminal conduct was occurring that an intrusion on the probationer's significantly diminished privacy interests was reasonable. 
  • The district court found, and defendant conceded, that the search was supported by reasonable suspicion. 
  • Thus, the court held that the warrantless search of defendant, supported by reasonable suspicion and authorized by a condition of probation, was reasonable within the meaning of the Fourth Amendment.

The judgment of the court of appeals was reversed, and the cause was remanded for further proceedings.

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

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