What is the test for validating a search under the probation clause?

3. We observed that different officers presented with the same facts may harbor varying motivations in deciding to search a probationer's house pursuant to a known search condition; thus, focusing on subjective intent would likely lead to disparate results in factually comparable situations. (People v. Woods, supra, 21 Cal.4th at pp. 680-681, 88 Cal. Rptr.2d 88, 981 P.2d 1019.) Moreover, since officers who rely on a probation clause must confine the scope of their search to the terms articulated in the clause and to those areas of the residence over which they reasonably believe the probationer has access or control, we concluded "there is little to be advanced by validating a search merely upon the searching officer's ability to convincingly articulate the proper subjective motivation for his or her actions." (Id. at p. 681, 88 Cal. Rptr.2d 88, 981 P.2d 1019.)

4. Footnote 6 of People v. Woods, supra, 21 Cal.4th at page 679, 88 Cal.Rptr.2d 88, 981 P.2d 1019, lends no support to the People's position. It merely acknowledged the potential for the type of argument advanced here, while stating explicitly that the opinion addressed only the factual scenario presented in that case. (Ibid.)

5. Initially we determined the search could not be validated on an advance consent theory (see People v. Bravo, supra, 43 Cal.3d 600, 238 Cal.Rptr. 282, 738 P.2d 336), for a juvenile, unlike an adult, has no choice whether or not to accept a condition of probation that subjects him or her to a warrantless search. (Tyrell J., supra, 8 Cal.4th at pp. 81-83, 32 Cal.Rptr.2d 33, 876 P.2d 519.)