Cal.1: Parole searches in CA only require any officer have knowledge defendant is on supervision, not even the conditions

For a parole search in California, it’s only required that the officer objectively reasonably know that the defendant is on post-release community supervision (PRCS) not even the conditions. People v. Douglas, 2015 Cal. App. LEXIS 840 (1st Dist. September 28, 2015):

[A]n individual who has been released from custody under PRCS [post-release community supervision] is subject to search (and detention incident thereto) so long as the officer knows the individual is on PRCS. PRCS, like parole, involves the post-incarceration supervision of individuals whose crimes were serious enough to result in a prison sentence and thereby implicates important public safety concerns, as well as the state’s “‘“overwhelming”’” interest in supervising released inmates. (Samson, supra, 547 U.S. at p. 853.) It is not necessary for the officer to recite or for the People to prove the precise terms of release, for the search condition is imposed by law, not by consent. As in the case of a parole search, an officer’s knowledge that the individual is on PRCS is equivalent to knowledge that he or she is subject to a search condition. (Cf. Middleton, supra, 131 Cal.App.4th at p. 739.)

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