S.D.N.Y.: Parolee’s curfew violation justified parole search

A stop and search of a parolee for a curfew violation was reasonable. United States v. Joseph, 2021 U.S. Dist. LEXIS 32456 (S.D. N.Y. Feb. 22, 2021).

Officers entered with an arrest warrant and later followed up with a search warrant. The record is clear that the officer’s search warrant was properly issued on separate probable cause with an independent source. “Instead, Judge Navarre’s probable-cause determination was made only through consideration of facts which Buckingham concedes were untainted by any alleged constitutional violation.” United States v. Buckingham, 2021 U.S. Dist. LEXIS 32366 (N.D. Ohio Feb. 22, 2021).*

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