What is the scope of a probation search?

Probation searches may be conducted to further the rehabilitative and reformative purposes of probation and other legitimate law enforcement purposes. (See 1203.1, subd. (j).) "A waiver of Fourth Amendment rights as a condition of probation does not permit searches undertaken for harassment or searches for arbitrary or capricious reasons." (People v. Bravo (1987) 43 Cal.3d 600, 610.) Due to the large amount of unrelated data that can be held on a cell phone or other electronic device, and to comply

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