CA11: Suspicionless parole searches of cell phone and home here were proper

The parole search of defendant’s home and cell phone was permitted by Samson. He’d signed a parole search waiver that permitted a search at any time. Also, the officers had reasonable suspicion, but Samson doesn’t require that if the parolee knows reasonable suspicion isn’t required. United States v. Johnson, 2014 U.S. App. LEXIS 17745 (11th Cir. September 16, 2014).

Officers thought defendant might be casing a liquor store for a New Years Eve robbery, and they drove up and asked, not told, him to show his hands. They also asked if he had a gun, and he admitted that he did. This was not a seizure. United States v. Preston, 2014 U.S. App. LEXIS 17734, 2014 FED App. 0718N (6th Cir. September 12, 2014).*

Shipped packages that came through customs at JFK in New York were delivered to Buffalo. The search at Buffalo still qualified as an extended border search. United States v. Reed, 2014 U.S. Dist. LEXIS 126024 (W.D. N.Y. September 9, 2014).*

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