U.S. v. Knights, 001260

CourtUnited States Supreme Court
Writing for the CourtRehnquist
Citation151 L.Ed.2d 497,122 S.Ct. 587,534 U.S. 112
Decision Date10 December 2001
Docket Number001260
Parties UNITED STATES, PETITIONER v. MARK JAMES KNIGHTSSupreme Court of the United States

534 U.S. 112
122 S.Ct. 587
151 L.Ed.2d 497

NOTICE: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order that corrections may be made before the preliminary print goes to press.

UNITED STATES, PETITIONER
v.
MARK JAMES KNIGHTS

No. 00-1260.

Supreme Court of the United States

Argued November 6, 2001
Decided December 10, 2001

Syllabus

A California court's order sentencing respondent Knights to probation for a drug offense included the condition that Knights submit to search at anytime, with or without a search or arrest warrant or reasonable cause, by any probation or law enforcement officer. Subsequently, a sheriff's detective, with reasonable suspicion, searched Knights's apartment. Based in part on items recovered, 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 Ninth Circuit affirmed.

Held: The warrantless search of Knights, supported by reasonable suspicion and authorized by a probation condition, satisfied the Fourth Amendment. As nothing in Knights's probation condition limits searches to those with a "probationary" purpose, the question here is whether the Fourth Amendment imposes such a limitation. Knights argues that a warrantless search of a probationer satisfies the Fourth Amendment only if it is just like the search at issue in Griffin v. Wisconsin, 483 U.S. 868, i.e., a "special needs" search conducted by a probation officer monitoring whether the probationer is complying with probation restrictions. This dubious logic that an opinion upholding the constitutionality of a particular search implicitly holds unconstitutional any search that is not like it runs contrary to Griffin's express statement that its "special needs" holding made it "unnecessary to consider whether" warrantless searches of probationers were otherwise reasonable under the Fourth Amendment. Id., at 878, 880. And this Court need not decide whether Knights's acceptance of the search condition constituted consent to a complete waiver of his Fourth Amendment rights in the sense of Schneckloth v. Bustamonte, 412 U.S. 218, because the search here was reasonable under the Court's general Fourth Amendment "totality of the circumstances" approach, Ohio v. Robinette, 519 U.S. 33, 39, with the search condition being a salient circumstance. The Fourth Amendment's touchstone is reasonableness, and a search's reasonableness is determined by assessing, on the one hand, the degree to which it intrudes upon an individual's privacy and, on the other, the degree to which it is needed to promote legitimate governmental interests. Wyoming v. Houghton, 526 U.S. 295, 300. Knights's status as a probationer subject to a search condition informs both sides of that balance. The sentencing judge reasonably concluded that the search condition would further the two primary goals of probation rehabilitation and protecting society from future criminal violations. Knights was unambiguously informed of the search condition. Thus, Knights's reasonable expectation of privacy was significantly diminished. In assessing the governmental interest, it must be remembered that the very assumption of probation is that the probationer is more likely than others to violate the law. Griffin, supra, at 880. The State's interest in apprehending criminal law violators, thereby protecting potential victims, may justifiably focus on probationers in a way that it does not on the ordinary citizen. On balance, no more than reasonable suspicion was required to search this probationer's house. The degree of individualized suspicion required is a determination that a sufficiently high probability of criminal conduct makes the intrusion on the individual's privacy interest reasonable. Although the Fourth Amendment ordinarily requires probable cause, a lesser degree satisfies the Constitution when the balance of governmental and private interests makes such a standard reasonable. See, e.g., Terry v. Ohio, 392 U.S. 1. The same circumstances that lead to the conclusion that reasonable suspicion is constitutionally sufficient also render a warrant requirement unnecessary. See Illinois v. McArthur, 531 U.S. 326, 330. Because the Court's holding rests on ordinary Fourth Amendment analysis that considers all the circumstances of a search, there is no basis for examining official purpose. Pp. 4-9.219 F.3d 1138, reversed and remanded.

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Rehnquist, C. J., delivered the opinion for a unanimous Court.

Opinion of the Court

Chief Justice Rehnquist delivered the opinion of the Court.

A California court sentenced respondent Mark James Knights to summary probation for a drug offense. The probation order...

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1612 practice notes
  • Legal Issues Relating To The Testing, USE, and Deployment of An Intrusion-Detection System (Einstein 2.0) To Protect Unclassified Computer Networks In The Executive Branch, 09-1
    • United States
    • Opinions of the Office of Legal Counsel of the Department of Justice
    • January 9, 2009
    ...the reasonableness of EINSTEIN 2.0 operations is measured in light of the "totality of the circumstances, " United States v. Knights, 534 U.S. 112, 118 (2001), in "the context within which a search takes place, " New Jersey v. T.L.O., 469 U.S. 325, 337 (1985). In the context of a workplace ......
  • Doe v. Nebraska, Nos. 8:09CV456
    • United States
    • United States District Courts. 8th Circuit. United States District Court of Nebraska
    • October 17, 2012
    ...needs to search to promote its legitimate interests.United States v. Brown, 346 F.3d 808, 811 (8th Cir.2003). In United States v. Knights, 534 U.S. 112, 119–21, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001), the Supreme Court noted that probationers “do not enjoy the absolute liberty to which every......
  • Reid v. Pautler, No. CIV 13-0337 JB/KBM
    • United States
    • United States District Courts. 10th Circuit. District of New Mexico
    • July 31, 2014
    ...circumstances' to determine whether a search is reasonable within the meaning of the Fourth Amendment.")(quoting United States v. Knights, 534 U.S. 112, 118 (2001)). "Although the Fourth Amendment ordinarily requires the degree of probability embodied in the term 'probable cause,' a lesser ......
  • USA v. Arbert Pool, No. 09-10303.
    • United States
    • United States Courts of Appeals. United States Court of Appeals (9th Circuit)
    • September 14, 2010
    ...“examin[es] the totality of the circumstances to determine whether a search is reasonable.” Id. at 2197(quoting United States v. Knights, 534 U.S. 112, 118, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001)) (internal quotation marks omitted). “Whether a search is reasonable ‘is determined by assessing......
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1616 cases
  • Legal Issues Relating To The Testing, USE, and Deployment of An Intrusion-Detection System (Einstein 2.0) To Protect Unclassified Computer Networks In The Executive Branch, 09-1
    • United States
    • Opinions of the Office of Legal Counsel of the Department of Justice
    • January 9, 2009
    ...the reasonableness of EINSTEIN 2.0 operations is measured in light of the "totality of the circumstances, " United States v. Knights, 534 U.S. 112, 118 (2001), in "the context within which a search takes place, " New Jersey v. T.L.O., 469 U.S. 325, 337 (1985). In the context of a workplace ......
  • Doe v. Nebraska, Nos. 8:09CV456
    • United States
    • United States District Courts. 8th Circuit. United States District Court of Nebraska
    • October 17, 2012
    ...needs to search to promote its legitimate interests.United States v. Brown, 346 F.3d 808, 811 (8th Cir.2003). In United States v. Knights, 534 U.S. 112, 119–21, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001), the Supreme Court noted that probationers “do not enjoy the absolute liberty to which every......
  • Reid v. Pautler, No. CIV 13-0337 JB/KBM
    • United States
    • United States District Courts. 10th Circuit. District of New Mexico
    • July 31, 2014
    ...circumstances' to determine whether a search is reasonable within the meaning of the Fourth Amendment.")(quoting United States v. Knights, 534 U.S. 112, 118 (2001)). "Although the Fourth Amendment ordinarily requires the degree of probability embodied in the term 'probable cause,' a lesser ......
  • USA v. Arbert Pool, No. 09-10303.
    • United States
    • United States Courts of Appeals. United States Court of Appeals (9th Circuit)
    • September 14, 2010
    ...“examin[es] the totality of the circumstances to determine whether a search is reasonable.” Id. at 2197(quoting United States v. Knights, 534 U.S. 112, 118, 122 S.Ct. 587, 151 L.Ed.2d 497 (2001)) (internal quotation marks omitted). “Whether a search is reasonable ‘is determined by assessing......
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4 books & journal articles
  • Deportation Arrest Warrants.
    • United States
    • February 1, 2021
    ...Brigham City v. Stuart, 547 U.S. 398,403 (2006); see also Riley v. California, 573 U.S. 373, 381-82 (2014); United States v. Knights, 534 U.S. 112, 118-19 (105.) See, e.g., Wilson v. Arkansas, 514 U.S. 927, 934, 936 (1995); cf. Groh v. Ramirez, 540 U.S. 551, 571-72 (2004) (Thomas, J., disse......
  • THE ORIGINS AND LEGACY OF THE FOURTH AMENDMENT REASONABLENESS-BALANCING MODEL.
    • United States
    • Case Western Reserve Law Review Vol. 71 Nbr. 1, September 2020
    • September 22, 2020
    ...Dressier, David Kaye, and George Thomas for their thoughtful comments on an earlier draft of this Article. (1.) United States v. Knights, 534 U.S. 112, 118 (2.) U.S. CONST, amend. IV (providing that "[t]he right of the people to be secure in their persons, houses, papers, and effects, again......
  • Law Enforcement Case Law
    • United States
    • Criminal Justice Review Nbr. 30-2, September 2005
    • September 1, 2005
    ...469 U.S. 478 (1985).U.S. v. Johnson, 351 F.3d 254 (6th Cir. 11-04-03).U.S. v. Kincade, 379 F.3d 813 (9th Cir. 10-02-04).U.S. v. Knights, 534 U.S. 112 (2001).U.S. v. Leon, 468 U.S. 897 (1984).U.S. v. Maldonado, 356 F.3d 130 (1st Cir. 01-20-04).U.S. v. Manjarrez, 348 F.3d 881 (10th Cir. 11-04......
  • IS JUVENILE PROBATION OBSOLETE? REEXAMINING AND REIMAGINING YOUTH PROBATION LAW, POLICY, AND PRACTICE.
    • United States
    • Journal of Criminal Law and Criminology Vol. 112 Nbr. 3, June 2022
    • June 22, 2022
    ...Conditions, 8 NEW ENG. J. ON PRISON L. 367, 374 (1982). (186) Id. (187) See Griffin v. Wisconsin, 483 U.S. 868, 872-80 (1987). (188) 534 U.S. 112, (189) See Rothman, supra note 180, at 841^2. (190) Id. at 841. (191) See United States v. Keith, 375 F.3d 346, 350 (5th Cir. 2004); United State......

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