The collection of officers from several law enforcement agencies for a probation “compliance check” shows that it wasn’t a bona fide probation search. “Given the totality of the circumstances, the compliance check was unreasonably pretextual. Agents Bertrand and Hardy should not have been in Mr. Julien’s bedroom and thereby able to view the ammunition in plain sight. The legality of the search conducted thereafter was vitiated by the fact that neither Agent Bertrand, nor Hardy was assigned as Mr. Julien’s probation officer, which triggered La. C.Cr.P. art. 895(A)(13)(a). Once implicated, La. C.Cr.P. art. 895(A)(13)(a) requires that the warrantless search be conducted by the probation officer assigned to Mr. Julien. It is undisputed that the probation officer assigned to Mr. Julien was not present.” State v. Julien, 2017 La. App. LEXIS 430 (La.App. 4 Cir. March 15, 2017).
Another Playpen warrant sustained. United States v. Hachey, 2017 U.S. Dist. LEXIS 34192 (E.D. Pa. March 7, 2017).*