Analyzing all the probation and parole search cases, the court finds defendant’s claim that probation was really a “stalking horse” for ATF unavailing. He had a reduced expectation of privacy and that there was reasonable suspicion for the search in the first place. The “stalking horse” rationale is not universally accepted. United States v. Price, 2019 U.S. Dist. LEXIS 180258 (S.D. Ind. Oct. 18, 2019).
Defendant voluntarily told police officers during a stop that she had drugs on her person, and that led to a search of the car. The district court held that this was all voluntary, and the court of appeals agrees. The officers told her that they knew she’d be off buying drugs in Knoxville. UUnited States v. West, 2019 U.S. App. LEXIS 31045 (6th Cir. Oct. 18, 2019).*