What is the test for a warrantless electronic search condition of probation?

California, United States of America


The following excerpt is from People v. T.C. (In re T.C.), H046222 (Cal. App. 2019):

"We recognize that [a juvenile's] probation status does not completely vitiate his constitutional privacy rights. [Citation.] However, the fact that a search of an electronic device may uncover comparatively more private information than the search of a person, or a personal item like a wallet, does not establish that a warrantless electronic search condition of probation is per se unconstitutional." (People v. Guzman (2018) 23 Cal.App.5th 53, 65, fn. omitted, citing People v. Ebertowski (2014) 228 Cal.App.4th 1170.) The probation conditions upheld against an overbreadth challenge in Ebertowski

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