People v. Schmitz
Annotate this CaseThis case involved the constitutional limits of a vehicle search based on a passenger's parole status. Here, an officer, aware that the front seat passenger was on parole, searched the back seat of Defendant's car and recovered drugs and drug paraphernalia from a chips bag and a pair of shoes. Defendant, the driver, sought to suppress that evidence. Defendant's suppression motion was denied, and Defendant pleaded guilty to four misdemeanor counts. The court of appeal reversed, holding that the search could not be justified on the basis of the front seat passenger's parole status. The Supreme Court reversed, holding that the search was reasonable under the Fourth Amendment where (1) the Constitutional permits a search of those areas of the passenger compartment where the officer reasoanbly expects that the parolee could have stowed personal belongings or discarded items when aware of police activity; and (2) additionally, the officer may search personal property located in those areas if the officer reasonably believes that the parolee owns those items or has the ability to exert control over them.
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