United States v. Knights

Mark James Knights (defendant) was on probation for a drug conviction, subject to a signed condition allowing any officer to search his person or property without a warrant or reasonable cause. A detective suspecting Knights and Steven Simoneau of vandalizing utility company property saw suspicious materials in Simoneau's truck parked at Knights's home and searched Knights's apartment without a warrant, relying on the probation search condition, finding bomb-making materials and vandalism evidence. The district court suppressed the evidence, reasoning the search was investigative rather than probationary, and the Ninth Circuit affirmed.