California v. Patton
Annotate this CaseDefendant Kayvon Patton pleaded guilty to grand theft of personal property and was sentenced to three years of formal probation. Among the conditions of probation was a condition subjecting his electronic devices to warrantless search. Patton challenged this condition as unreasonable under California v. Lent, 15 Cal.3d 481 (1975) and unconstitutionally overbroad. After review, the Court of Appeal concluded the electronic device search condition was properly imposed. Patton pleaded guilty to stealing electronic devices, cell phones and other items, so that he could buy drugs. “There is a direct and manifestly reasonable relationship between the electronic device search condition and both the crime of which Patton was convicted as well as the underlying reasons for his criminal behavior such that the condition will assist in preventing future criminality. And while searches of electronic devices surely implicate privacy interests, a condition of probation permitting examination of such devices without a warrant is not unconstitutionally overbroad on its face.”
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