What is the test for a search warrant under the Fourth Amendment?

"A warrantless search is unreasonable under the Fourth Amendment unless it is conducted pursuant to one of the few narrowly drawn exceptions to the constitutional requirement of a warrant. [Citations.]" (People v. Schmitz (2012) 55 Cal.4th 909, 916.) A search pursuant to a valid term of probation is an exception to the warrant requirement, and if established, requires no further justification. (People v. Woods (1999) 21 Cal.4th 668, 674-675.)

"Our review of issues related to the suppression of evidence seized by the police is governed by federal constitutional standards. [Citations.]" (People v. Lenart (2004) 32 Cal.4th 1107, 1119.) "In reviewing the trial court's suppression ruling, we defer to its factual findings if supported by substantial evidence. We independently assess the legal question of whether the challenged search or seizure satisfies the Fourth Amendment. [Citation.]" (People v. Brown, supra, 61 Cal.4th at p. 975.)