## Facts

- Fairfield police observed a car make turns and pull to the curb without signaling; the prosecution conceded these acts alone did not justify a stop because no other traffic was affected.
- Two passengers exited the car; an officer detained and questioned them due to recent gang violence in the area.
- Jaime P., a minor, was the driver; when contacted, he produced only a school ID and said he did not have a driver’s license.
- The officer saw a box of ammunition in plain view on the front floorboard.
- Officers ordered all occupants out and conducted pat-down searches; a padlock tied to a bandana was found on one passenger.
- Because no occupant had a valid driver’s license, the officer arranged for the vehicle to be towed and stored; a subsequent vehicle search led to discovery of a firearm and related juvenile wardship allegations.
- The juvenile court denied Jaime’s motion to suppress the firearm and ammunition evidence and sustained allegations including carrying a loaded firearm with a gang enhancement.
- The California Supreme Court granted review to reconsider whether a juvenile probation search condition unknown to the searching officer can validate a warrantless search.

## Issues

1. Whether a warrantless search may be upheld based solely on a juvenile probation search condition that was unknown to the officer at the time of the search.
2. Whether prior precedent permitting such post hoc reliance on an unknown juvenile probation search condition should remain valid.

## Decision

- The California Supreme Court overruled *In re Tyrell J.*.
- The Court held that a search cannot be justified after the fact by a juvenile probation search condition unknown to the officer when the search occurred.
- The Court reasoned that subsequent authority, including *People v. Sanders* and *Samson v. California*, required treating officer knowledge of the search condition as constitutionally significant for Fourth Amendment reasonableness.
- The Court aligned juvenile probation-search doctrine with the rule applied to adult probation searches in *Sanders*: a search condition supports a warrantless search only when officers know of it at the time or when another independent justification exists.

## Legal Principles

- A probation search condition cannot supply Fourth Amendment reasonableness for a warrantless search when the searching officer is unaware of the condition at the time of the search.
- Courts may not uphold a search on a probation-condition theory based on facts not known to officers when they acted; after-the-fact justification is improper.
- Juvenile probationers’ reduced expectations of privacy do not support a separate rule permitting unknown-condition searches; the same contemporaneous-knowledge requirement applies.

## Conclusion

The decision rejected and overruled the rule permitting warrantless searches of juvenile probationers to be validated by an unknown probation search condition, requiring that such conditions justify a search only when officers know of them at the time or the search rests on an independent lawful basis.


In re Jaime P., 40 Cal. 4th 128 (Cal. 2006)