Defendant’s girlfriend was on parole, and the parole officers came to the house for a search. The parole officers reasonably believed that she had apparent authority to consent to a search of the premises. She believed she was moving there, she had a key, and she never attempted to limit the search. People v. Peluso, 2021 CO 16, 2021 Colo. LEXIS 153 (Mar. 8, 2021).
The Arkansas statute permitted warrantless parole and probation searches is not unconstitutional because such searches are permitted under Samson and Knights. Knights interpreted a California statute similar to Arkansas’s. The special needs exception applies. Clingmon v. State, 2021 Ark. App. 107, 2021 Ark. App. LEXIS 134 (Mar. 10, 2021).