## Facts

- Joseph G. Griffin was on probation under Wisconsin regulations placing probationers in state custody and subject to departmental conditions.
- A Wisconsin regulation authorized a probation officer to search a probationer’s residence without a warrant if a supervisor approved and there were “reasonable grounds” to believe contraband was present.
- Another regulation prohibited a probationer from possessing a firearm without advance approval from the probation officer.
- Griffin’s probation officer received information from a police detective that there were or might be guns in Griffin’s apartment.
- With supervisory approval, probation officers conducted a warrantless search of Griffin’s apartment and found a handgun.
- Griffin was charged with felony possession of a firearm by a convicted felon and moved to suppress the handgun as the product of an unconstitutional search.
- The trial court denied suppression; Griffin was convicted; Wisconsin appellate courts affirmed.

## Issues

1. Whether the Fourth Amendment permits a warrantless search of a probationer’s home conducted under a state probation regulation and based on “reasonable grounds” rather than probable cause.

## Decision

- The Supreme Court affirmed in a 5–4 decision (Justice Scalia).
- The Court held the warrantless search did not violate the Fourth Amendment because it was reasonable under a regulation that satisfied Fourth Amendment reasonableness.
- The Court treated probation supervision as a “special needs” setting that can justify departure from ordinary warrant and probable-cause requirements.
- The Court found the search complied with the regulation: supervisory approval was obtained and the detective’s report supplied reasonable grounds, especially given probation limits on firearm possession.

## Legal Principles

- The Fourth Amendment’s reasonableness requirement may be satisfied by a warrantless probation search conducted under a valid regulatory scheme when special needs beyond ordinary law enforcement make warrant and probable-cause requirements impracticable.
- Probationers have diminished liberty and privacy interests, permitting closer supervision to enforce probation conditions, support rehabilitation, and protect the community.
- A regulation-based “reasonable grounds” standard may constitutionally substitute for probable cause when structured to limit arbitrary searches (including consideration of information reliability, specificity, and supervision needs).
- Warrant requirements may be dispensed with when they would materially interfere with probation administration by slowing responses to misconduct and shifting supervision judgments away from probation authorities.

## Conclusion

The Court upheld a warrantless search of a probationer’s home authorized by Wisconsin probation regulations, concluding that probation supervision presents special needs that permit warrantless searches on reasonable grounds when conducted within a structured supervisory framework.


Griffin v. Wisconsin, 483 U.S. 868 (1987)