WA: There must be a nexus between the scope of a parole search and what is being looked for

“¶17 We agree with [State v. Jardinez, 184 Wn. App. 518, 338 P.3d 292 (2014)] that the [Sentencing Guidelines] Commission’s comment is strong evidence that the legislature intended that there must be a nexus between the suspected violation and the searched property. Accordingly, we adopt the approach in Jardinez and hold that a valid search under RCW 9.94A.631(1) requires that there be a nexus between the alleged violation and the searched property.” Without it, the search is unreasonable. State v. Livingston, 2017 Wash. App. LEXIS 75 (Jan. 18, 2017).

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