Business Law

Facts: A California court's order sentencing respondent Knights to probation for a drug offense included the condition that Knights submit to search at anytime, with or without a search, arrest warrant, or reasonable cause, by any probation or law enforcement officer. Subsequently, a sheriff's detective, with reasonable suspicion, searched Knights's apartment. Based in part on items recovered, a federal grand jury indicted Knights for conspiracy to commit arson, for possession of an unregistered destructive device, and for being a felon in possession of ammunition. In granting Knights's motion to suppress, the District Court held that, although the detective had “reasonable suspicion” to believe that Knights was involved with incendiary materials, the search was for “investigatory” rather than “probationary” purposes. The Ninth Circuit affirmed the statement. Three days after Knights was placed on probation, a Pacific Gas & Electric power transformer and adjacent Pacific Bell telecommunications vault near the Napa County Airport were pried open and set on fire, causing an estimated $1.5 million in damage. Brass padlocks had been removed and a gasoline accelerant had been used to ignite the fire. Suspicion for these acts had long been focused on Knights and his friend, Steven Simoneau. The incidents began after PG had filed a theft-of-services complaint against Knights and discontinued his electrical service for failure to pay his bill. Detective Todd Hancock of the Napa County Sheriff's Department had noticed that the acts of vandalism coincided with Knights's court appearance dates concerning the theft of PG’s services. Then just a week before the arson, a sheriff's deputy had stopped Knights and Simoneau near a PG gas line and observed pipes and gasoline in Simoneau's pickup truck. After the PG arson, a sheriff's deputy drove by Knights's residence, where he saw Simoneau's truck parked in front. The deputy felt the hood of the truck. It was warm. Detective Hancock decided to set up surveillance of Knights's apartment. At about 3:10 the next morning, Simoneau exited the apartment carrying three cylindrical items. Detective Hancock believed the items were pipe bombs. Simoneau walked across the street to the bank of the Napa River. The next thing Hancock heard was three splashes. Simoneau returned without the cylinders and drove away in his truck. Simoneau then stopped in a driveway, parked, and left the area. Detective Hancock entered the driveway and observed a number of suspicious objects in the truck: a Molotov cocktail and explosive materials, a gasoline can, and two brass padlocks that fit the description of those removed from the PG transformer vault. After viewing the objects in Simoneau's truck, Detective Hancock decided to conduct a search of Knights's apartment. Detective Hancock was aware of the search condition in Knights's probation order and thus believed that a warrant was not necessary. The search revealed a detonation cord, ammunition, liquid chemicals, instruction manuals on chemistry and electrical circuitry, bolt cutters, telephone pole-climbing spurs, drug paraphernalia, and a brass padlock stamped with the company’s PG logo.

Issues/Rulings: The United States was faced to determine Knights’s guilt based upon three interconnected charges that had a lot to do with the Fourth Amendment, conspiracy to commit arson, possession of an unregistered destructive device, and being a felon in possession of ammunition. The imperative question at hand is: Did the sheriff’s deputy have reasonable suspicion to search Knights’s premises? The United States affirmed the lower court’s decision and ruled that the sheriff’s deputy did have the right to search Knights’s premises based upon reasonable suspicion alone, making all three charges applicable. The search condition states that Knights will submit to a search by a probation officer or any law affiliated officer.

Rules of Law: The United States based their opinion on three rules of law. The Fourth Amendment served as the foundation for the entire proceeding, while the probation order that Knights signed acted as the second. The third rule of law that was used to justify all three of the charges that were brought against Knights was the use of previous trials, their proceedings, and their rulings. “’The touchstone of the Fourth Amendment is reasonableness, and the reasonableness of a search is determined by assessing, on the one hand, the degree to which it intrudes