## Facts

- A juvenile delinquency petition alleged Curtis T. unlawfully possessed cocaine, and he was released on home supervision under a written agreement signed by him and his mother.
- The agreement included an access condition permitting probation supervision access to Curtis (and related compliance records).
- A probation officer called the home; Curtis’s mother stated Curtis was not at home, a violation of home-supervision conditions.
- The probation officer went to the home the next morning with another probation officer and two police officers to take Curtis into custody for the violation.
- Curtis’s mother admitted the officers into the living room.
- Testimony conflicted on whether the mother asked officers to wait while she woke Curtis or instead directed them toward the bedroom; the juvenile court resolved the conflict against Curtis.
- In Curtis’s bedroom, an officer saw car stereo equipment on the floor; inspection revealed obliterated serial numbers.
- Curtis moved to suppress the stereo evidence under the Fourth Amendment; the juvenile court denied the motion.
- Curtis admitted possessing equipment with obliterated serial numbers (Penal Code § 537e) and was declared a ward of the court; he appealed the suppression ruling.

## Issues

1. Whether officers lawfully entered Curtis’s bedroom while attempting to take him into custody for a home-supervision violation, based on the home-supervision access condition and/or parental consent.
2. Whether the stereo equipment with obliterated serial numbers was admissible under the plain-view doctrine once officers were in the bedroom.
3. Whether Curtis retained a reasonable expectation of privacy in his bedroom while on home supervision that required suppression of the evidence.

## Decision

- The Court of Appeal affirmed the denial of the suppression motion and the wardship order.
- Substantial evidence supported the juvenile court’s implied finding that the mother consented to the officers’ movement from the living room to the bedroom.
- The home-supervision access condition and authority to take Curtis into custody for violating release conditions supported the officers’ entry to locate him.
- Because officers were lawfully present in the bedroom, the stereo equipment was properly observed and seized under the plain-view doctrine.

## Legal Principles

- On review of a suppression ruling, appellate courts defer to the trial court’s supported factual findings (including credibility determinations) and independently apply Fourth Amendment law to those facts.
- A juvenile released from detention on home supervision has a reduced expectation of privacy consistent with supervision conditions accepted in exchange for conditional liberty.
- Valid third-party consent by a parent or guardian can authorize officers’ entry into areas of the home within the scope of that consent, as found by the factfinder.
- Under the plain-view doctrine, officers may seize evidence without a warrant when they are lawfully present, the item is in plain view, and its incriminating character is apparent.

## Conclusion

The court upheld admission of stereo equipment found in a minor’s bedroom because officers entered to take him into custody for violating home-supervision conditions, the juvenile court found the mother consented to their entry, and the items were discovered in plain view while officers were lawfully present.


In re Curtis T., 214 Cal. App. 3d 1391, 263 Cal. Rptr. 296 (Ct. App. 1989)