POs found defendant parolee at his girlfriend’s house that he was not approved to live in. It was arguable he didn’t have standing, and his reasonable expectation of privacy was reduced there [I think he would have standing as an overnight guest, but that’s not the point. The point is that the search could happen in his own home, so it could happen elsewhere, too.] but he was on parole because of his status. They had reasonable suspicion. The fact the officers entered a third party’s home doesn’t make the parole search unreasonable. United States v. Curtis, 2017 U.S. Dist. LEXIS 189055 (E.D. N.C. Oct. 10, 2017):
In sum, Defendant Curtis was on post-release supervision and the terms of that supervision restricted his liberty. A multi-agency search team, including at least two North Carolina probation/parole officers, was informed by a local police officer on that search team that Curtis was not residing at his approved residence but was living at different location and selling drugs from that location. The search team then went to that other location, entered a third-party’s residence, located Curtis, and arrested and searched him, locating contraband. Curtis’ privacy interest in the third party’s residence does not, considering the totality of the circumstances as described above, outweigh the Government’s interest in public safety and reducing recidivism among parolees. Therefore, the search of Lakesha Evans’ home on December 13, 2016, was reasonable as regards Defendant Curtis, and accordingly, Curtis’ motion to suppress should be denied.