Even if defendant’s parole search was in aid of a criminal investigation, it was still reasonable. United States v. Barron, 2024 U.S. App. LEXIS 6336 (5th Cir. Mar. 15, 2024).

A warrant after a shooting showed no probable cause for going in the house. The shooting victim was found outside, and a protective sweep saw nothing: no victims, no blood, no weapons. “That Robinson was shot may suggest a crime has occurred, but the lack of information in the affidavit may not be able to support an inference that the shooting took place inside the home, or that evidence related to the shooting would be found in the home. When officers found Robinson, he was already outside his home and when they conducted their protective sweep, they found no evidence of a shooter, blood, or a weapon inside the house. Thus, the fact that Robinson was lying outside his house may be insufficient to support probable cause to search inside the house. Moreover, that a neighbor heard arguing coming from the property cannot, by itself, establish probable cause. Raised voices alone, without more information regarding the words spoken, particularly if there is a question whether the voices came from inside the house, cannot create probable cause to search a home. Lastly, Inv. Johnson’s statement that people who have been charged for narcotics in the past are likely to keep narcotics in their homes does not create probable cause. Such assumptions have been found insufficient for the much lower standard necessary for reasonable suspicion. See United States v. Black, 707 F.3d 531, 540-41 (4th Cir. 2013) (‘Fourth, with respect to the officers’ “Rule of Two” or “one-plus rule,” we would abdicate our judicial role if we took law enforcement-created rules as sufficient to establish reasonable suspicion.’). The Court, therefore, concludes that the allegation that Robinson’s father slammed and locked the door as the officers attempted to secure the residence is material.” United States v. Robinson, 2024 U.S. Dist. LEXIS 46640 (W.D.N.C. Mar. 15, 2024).*

“We conclude that the ‘special needs’ doctrine of the Fourth Amendment permits, when sufficiently supported by the record, the imposition of a special condition of supervised release that allows the probation officer to conduct a suspicionless search of the defendant’s person, property, vehicle, place of residence, or any other property under his or her control. However, the district court exceeded its discretion in imposing that special condition here because it failed to make the individualized assessment required to support the special condition under 18 U.S.C. § 3583(d), including a sufficient explanation as to how the condition is reasonably related in this particular case to the applicable statutory factors under 18 U.S.C. § 3553(a) and involves no greater deprivation of liberty than is reasonably necessary under those factors.” United States v. Oliveras, 2024 U.S. App. LEXIS 6226 (2d Cir. Mar. 15, 2024).

Around midnight, two officers in a cruiser saw Albert Jackson alone in a parked car. They pulled alongside, close enough so Jackson would have to squeeze to get out. One officer went to Jackson’s side of the car, while the other walked to Jackson’s passenger side. Both shined flashlights on Jackson. By boxing in and surrounding Jackson, the officers’ actions meant a reasonable person in his position would not feel free to leave. [¶] The officers explained why they took these steps. Jackson was wearing a ‘big bulky jacket’ on a ‘hot’ and ‘humid’ night. He ‘was seated kind of awkwardly in the driver’s seat.’ And when they approached in the dark and shined flashlights on him, he looked ‘uncomfortable and kind of nervous,’ ‘like he was surprised to see us.’ [Well, yeah.] The officers’ stated observations did not suggest criminal activity might be afoot. Jackson’s detention violated the Fourth Amendment.” People v. Jackson, 2024 Cal. App. LEXIS 185 (2d Dist. Mar. 15, 2024).*