UNITED STATES V. KNIGHTS 534 U.S. 112 (2001) CASE BRIEF

UNITED STATES V. KNIGHTS

534 U.S. 112 (2001)

NATURE OF THE CASE: This was an appeal by the United States from the suppression of evidence on a search of a probationer under reasonable suspicion.

FACTS: Knights (D) was sentenced to summary probation for a drug offense. The probation order stated that D would '[s]ubmit his ... person, property, place of residence, vehicle, personal effects, to search at any time, with or without a search warrant, warrant of arrest or reasonable cause by any probation officer or law enforcement officer.' D signed the order. Three days after D was placed on probation, a Pacific Gas & Electric (PG) 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. This incident was the latest in more than 30 recent acts of vandalism against PG facilities in Napa County. Suspicion for these acts had long focused on D and his friend, Steven Simoneau. The incidents began after PG had filed a theft-of-services complaint against D 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 D's court appearance dates concerning the theft of PG services. And just a week before the arson, a sheriff's deputy had stopped D 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 D'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 D'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, and Hancock heard 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 D's apartment. Detective Hancock was aware of the search condition in D'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 'PG.' D was arrested. The District Court held that Detective Hancock had 'reasonable suspicion' to believe that D was involved with incendiary materials. But, it granted the motion to suppress on the ground that the search was for 'investigatory' rather than 'probationary' purposes. The Court of Appeals for the Ninth Circuit affirmed.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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