“[P]arole agents have the authority to conduct a protective Terry frisk of non-parolees within the course of executing their statutorily imposed duties, so long as reasonable suspicion supports the agents’ conduct.” Here, POs entered the parolee’s house for a visit and saw defendant there. He made them a little nervous, and ultimately there was a patdown based on reasonable suspicion he was armed. The court relied on State v. Barnes, 1996 Ohio App. LEXIS 3847 (2d Dist. Sept. 6, 1996) and People v. Rios, 193 Cal. App. 4th 584, 122 Cal. Rptr. 3d 96 (5th Dist. 2011). They tried to get him to leave so they wouldn’t have to search him, too. Commonwealth v. Mathis, 2017 Pa. LEXIS 3194 (Nov. 22, 2017) (dissent1, dissent2)
Under Terry, reasonable suspicion alone is enough for a frisk. Other analogous rationales for reasonable suspicion are protective sweep under Maryland v. Buie and protective weapons search under Michigan v. Long.