Samson v. California

Samson v. California

When parolees are released from prison, their release is conditional. Often, the conditions of parole require significant intrusions on the freedoms of the parolee. In California, for example, parolees are required to agree in writing that they may be searched by police or parole officers, for any reason and at any time during the term of their parole. The constitutionality of this law was challenged in the Supreme Court case of Samson v. California, in which a man was searched based on no suspicion other than the fact that he was a parolee from a California state prison.

Parole and the Fourth Amendment

The Fourth Amendment of the United States Constitution forbids “unreasonable search and seizure.” Determining what constitutes an unreasonable search has been a matter that has been litigated repeatedly, for decades. In order for a police officer to conduct a search of someone's person or vehicle, they are generally required to have probable cause—that is, there needs to be a very convincing reason that they believe the person to be committing a criminal act.

Evidence that is gathered through a search that is determined to be unconstitutional cannot be used to convict a defendant in a court of law. This rule is called the exclusionary rule, and is designed to ensure that police departments do not have an incentive to conduct illegal searches and seizures of property in the hopes of securing a conviction regardless of the legality of the evidence obtained.

The Search and Trial of Samson

Donald Samson was on parole in 2002, following a term of imprisonment in state prison for possessing a firearm as a felon. In September of that year, he was noticed by a police officer who recognized him as being a parolee. After verifying with Samson that he was, in fact, currently released on parole, the officer conducted a physical search of Samson's person. A bag of methamphetamine was found in his pocket, and he was arrested and charged for drug possession.

At the trial, Samson's attorney motioned to suppress the evidence of methamphetamine possession, claiming it had resulted from a search that was unconstitutional according to the defendant's Fourth Amendment rights. However, the court denied the motion because according to California's parole statute, searches of parolees were permitted as long as they were not harassing.

Appeal and Supreme Court Ruling

Samson appealed his case. The appeals court—and later, the United States Supreme Court—upheld the district court's ruling in Samson v. California. According to the courts, as long as the search was not capricious, arbitrary, or harassing, it did not constitute an illegal search when the defendant was a parolee. The court ruled that because parolees had a choice between remaining in prison to serve out the duration of their sentences, or to be released early as long as they agreed to conditions, the state had wide discretion in determining these conditions.

The court ruled in Samson v. California that even though police are required to have reasonable suspicion to search someone who is on probation, the same rule does not apply to those on parole, who are technically to some extent imprisoned, albeit out of physical custody of the state.