An electronic search condition of probation is not per se unreasonable under Riley. Here, it was reasonable to show whether defendant ridded himself of his gang affiliations which was a condition of probation. People v. Guzman, 2018 Cal. App. LEXIS 422 (1st Dist. May 9, 2018).
Pennsylvania recognizes the “stalking horse” doctrine for parole searches, but this case doesn’t rise to that. The PO had reasonable suspicion and enlisted police to participate. Commonwealth v. Gould, 2018 PA Super 123, 2018 Pa. Super. LEXIS 453 (May 9, 2018).*