Sampson v. United States, 547 U.S. 843 (2006). · Go Syfert
Sampson v. United States, 547 U.S. 843 (2006). Cases Citing This Book View Copy Cite
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cited 3× by 2 distinct cases, 2014–2017 · 2 courts · …the touchstone of the fourth amendment is reasonableness, not individualized suspicion. ⚠ not in text
2,528 citation events (2,528 in the last 25 years) across 151 distinct courts.
Strongest positive: State v. Thomas (utahctapp, 2025-08-28) · Strongest negative: Murry v. Commonwealth (va, 2014-09-12)
Treatment trajectory · 2006 → 2026 · click a year to view as-of
2006 2016 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited "but see" Murry v. Commonwealth (3×) also: Cited "see, e.g."
Va. · 2014 · signal: but see · confidence high
But see Samson v. California, 547 U.S. 843, 857 (2006) (holding that "the Fourth Amendment does not prohibit a police officer from conducting a suspicionless search of a parolee").
examined Cited "but see" Murry v. Commonwealth (3×) also: Cited "see, e.g."
Va. · 2014 · signal: but see · confidence high
But see Samson v. California, 547 U.S. 843, 857 (2006) (holding that "the Fourth Amendment does not prohibit a police officer from conducting a suspicionless search of a parolee").
discussed Cited as authority (verbatim quote) State v. Thomas
Utah Ct. App. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
he fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee.
discussed Cited as authority (verbatim quote) United States v. Lowe
10th Cir. · 2024 · signal: see also · quote attribution · 1 verbatim quote · confidence high
cceptance of a clear and unambiguous search condition significantly diminishe reasonable expectation of privacy.
discussed Cited as authority (verbatim quote) Kellebrew v. Arkansas, State of
E.D. Ark. · 2024 · signal: see · quote attribution · 1 verbatim quote · confidence high
the fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee.
discussed Cited as authority (verbatim quote) Maddox, Jr. v. The Parole Commission of Maryland and its Agents
D. Maryland · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
arolees are on the 'continuum' of state-imposed punishments . . . have fewer expectations of privacy than probationers because parole is more akin to imprisonment.
examined Cited as authority (verbatim quote) United States v. Travis Beechler (3×) also: Cited as authority (rule)
7th Cir. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
the extent and reach of these conditions clearly demonstrate that parolees like petitioner have severely diminished expectations of pri- vacy by virtue of their status alone.
discussed Cited as authority (verbatim quote) Harris v. Ross
D. Maryland · 2023 · quote attribution · 1 verbatim quote · confidence high
arolees are on the 'continuum' of state- imposed punishments . . . have fewer expectations of privacy than probationers because parole is more akin to imprisonment.
examined Cited as authority (verbatim quote) United States v. Ronald Sharp (7×) also: Cited as authority (rule), Cited "see", Cited "see, e.g."
6th Cir. · 2022 · quote attribution · 1 verbatim quote · confidence high
he fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee.
discussed Cited as authority (verbatim quote) State v. Harbacek (2×) also: Cited "see"
Kan. Ct. App. · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
the essence of parole is release from prison, before the completion of sentence, on the condition that the prisoner abide by certain rules during the balance of the sentence.
discussed Cited as authority (verbatim quote) Sigal v. Bean (2×) also: Cited as authority (rule)
D. Nev. · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
acceptance of a clear and unambiguous search 12 condition significantly diminished reasonable expectation of privacy.
examined Cited as authority (verbatim quote) Gray v. Bansley / Anthony / Burdo LLC
D. Conn. · 2020 · signal: see also · quote attribution · 1 verbatim quote · confidence high
parole differs from probation insofar as parole is meted out in addition to, not in lieu of, incarceration ... nd, certainly, parolees typically will have committed more serious crimes ... than probationers.
examined Cited as authority (verbatim quote) Hoegemann v. Palma (2×)
D. Conn. · 2019 · signal: see also · quote attribution · 2 verbatim quotes · confidence high
the extent and reach of these conditions clearly demonstrate that parolees like petitioner have severely diminished expectations of privacy by virtue of their status alone.
examined Cited as authority (verbatim quote) State v. Grady (15×) also: Cited as authority (quoted), Cited as authority (rule), Cited "see", Cited "see, e.g."
N.C. · 2019 · signal: see also · quote attribution · 3 verbatim quotes · confidence high
this court has acknowledged the grave safety concerns that attend recidivism" and "the fourth amendment does not render the states powerless to address these concerns effectively .
examined Cited as authority (verbatim quote) United States v. Ibrahim Bare
9th Cir. · 2015 · quote attribution · 1 verbatim quote · confidence high
his court has repeatedly acknowledged that a state's interests in reducing recidivism and thereby promoting reintegration and positive citizenship among probationers and parolees warrant privacy intrusions that would not otherwise be tolerated under the fourth amendment.
examined Cited as authority (verbatim quote) United States v. Howard Cotterman (2×) also: Cited as authority (quoted)
9th Cir. · 2013 · signal: see · quote attribution · 2 verbatim quotes · confidence high
under our general fourth amendment approach, we examine the totality of the circumstances to determine whether a search is reasonable . . . .
examined Cited as authority (verbatim quote) Sanchez v. Canales (3×) also: Cited as authority (rule), Cited "see"
9th Cir. · 2009 · signal: see · quote attribution · 1 verbatim quote · confidence high
arolees . . . have severely diminished expectations of privacy by vir- tue of their status alone.
discussed Cited as authority (quoted) United States v. Nelson
5th Cir. · 2024 · quote attribution · 1 verbatim quote · confidence low
supervised release is akin to parole.
discussed Cited as authority (quoted) United States v. Nelson
5th Cir. · 2024 · quote attribution · 1 verbatim quote · confidence low
supervised release is akin to parole.
discussed Cited as authority (quoted) Allen v. Perkins
W.D. Ark. · 2023 · quote attribution · 1 verbatim quote · confidence low
samson ultimately held that a suspicionless search of a parolee pursuant to a california statute was constitutional
discussed Cited as authority (quoted) United States v. Muhtorov
10th Cir. · 2021 · quote attribution · 1 verbatim quote · confidence low
what is reasonable . . . depends on the nature of the search.
discussed Cited as authority (quoted) VIOLETTE v. TURGEON (2×) also: Cited as authority (rule)
D. Me. · 2020 · quote attribution · 1 verbatim quote · confidence low
totality of the circumstances analysis" is applied in "situation involving even a suspicionless search of a conditional releasee
discussed Cited as authority (quoted) United States v. Billy Curry, Jr. (2×) also: Cited "see"
4th Cir. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
the touchstone of the fourth amendment is reasonableness, not individual suspicion.
discussed Cited as authority (quoted) City of Cleveland v. Grunt
Ohio Ct. App. · 2018 · signal: see also · quote attribution · 1 verbatim quote · confidence low
parolees have severely diminished expectations of privacy by virtue of their status alone
examined Cited as authority (quoted) Commonwealth v. Jacoby, T., Aplt. (2×)
Pa. · 2017 · signal: see · quote attribution · 2 verbatim quotes · confidence high
the touchstone of the fourth amendment is reasonableness, not individualized suspicion.
discussed Cited as authority (quoted) United States v. Ramos
D.N.M. · 2016 · signal: see · quote attribution · 1 verbatim quote · confidence high
nder our general fourth amendment approach' we 'examin the totality of the circumstances' to determine whether a search is reasonable within the meaning of the fourth amendment,
examined Cited as authority (quoted) Salahuddin Smart v. Intensive Supervision Program
3rd Cir. · 2016 · signal: see also · quote attribution · 1 verbatim quote · confidence low
a condition of release can so diminish or eliminate a released prisoner's reasonable expectation of privacy that a suspicionless search by a law enforcement officer would not offend the fourth amendment.
discussed Cited as authority (quoted) Reid v. Pautler (2×) also: Cited as authority (rule)
D.N.M. · 2014 · signal: see · quote attribution · 1 verbatim quote · confidence high
nder our general fourth amendment approach' we 'examin the totality of the circumstances' to determine whether a search is reasonable within the meaning of' the fourth amendment.
discussed Cited as authority (quoted) Monica Bartley v. Florida Intracity Patrol, Inc.
11th Cir. · 2014 · signal: see also · quote attribution · 1 verbatim quote · confidence low
the touchstone of the fourth amendment is reasonableness, not individualized suspicion.
discussed Cited as authority (quoted) Tapia v. City of Albuquerque (2×) also: Cited as authority (rule)
D.N.M. · 2014 · signal: see · quote attribution · 1 verbatim quote · confidence high
nder our general fourth amendment approach' we 'examin the totality of the circumstances' to determine whether a search is reasonable within the meaning of the fourth amendment.
discussed Cited as authority (quoted) Tapia v. City of Albuquerque (2×) also: Cited as authority (rule)
D.N.M. · 2014 · signal: see · quote attribution · 1 verbatim quote · confidence high
nder our general fourth amendment approach' we 'examin the totality of the circumstances' to determine whether a search is reasonable within the meaning of the fourth amendment.
discussed Cited as authority (quoted) Ysasi v. Brown (2×) also: Cited as authority (rule)
D.N.M. · 2014 · signal: see · quote attribution · 1 verbatim quote · confidence high
the totality of the circumstances' to determine whether a search is reasonable within the meaning of the fourth amendment.
discussed Cited as authority (quoted) State v. Mark L. Ellis
Idaho Ct. App. · 2013 · quote attribution · 1 verbatim quote · confidence low
y virtue of their status alone, probationers do not enjoy the absolute liberty to which every citizen is entitled.
examined Cited as authority (quoted) State of Iowa v. Christine Ann Kern (6×) also: Cited "see", Cited "see, e.g."
Iowa · 2013 · signal: see · quote attribution · 2 verbatim quotes · confidence high
e conclude that petitioner did not have an 20 expectation of privacy that society would recognize as legitimate.
discussed Cited as authority (quoted) United States v. Frederick Lynch
3rd Cir. · 2012 · signal: see also · quote attribution · 1 verbatim quote · confidence low
he fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee.
discussed Cited as authority (quoted) United States v. Smith
8th Cir. · 2011 · signal: cf. · quote attribution · 1 verbatim quote · confidence low
imposing a reasonable suspicion requirement ... would give parolees greater opportunity to anticipate searches and conceal criminality.
discussed Cited as authority (rule) Timothy J. Hampton v. City of Madison Police Department, Anthony Ciufo, S. Clennon, G. Sosoka, Schmidt’s Towing Company and John Doe #1
W.D. Wis. · 2026 · confidence medium
If so, he must provide more information about the search itself, such as whether: he was on supervision at the time or was arrested during the incident, see Samson v. California, 547 U.S. 843, 850 (2006) (warrantless search of probationer’s apartment reasonable under the Fourth Amendment), or if the officers presented a warrant for the search.
cited Cited as authority (rule) Charles King, III v. United States
11th Cir. · 2026 · confidence medium
Id. at 852.
discussed Cited as authority (rule) Dept. Pub. Safety & Corr. Svcs v. Proctor
Md. Ct. Spec. App. · 2026 · confidence medium
See e.g., Hudson v. Palmer, 468 U.S. 517, 526 (1984) (holding “the Fourth Amendment proscription against unreasonable searches does not apply within the confines of the prison cell” because “[t]he recognition of privacy rights for prisoners in their individual cells simply cannot be reconciled with the concept 23 of incarceration and the needs and objectives of penal institutions.”); Samson v. California, 547 U.S. 843, 852-57 (2006); McFarlin v. State, 409 Md. 391, 407 (2009).
discussed Cited as authority (rule) State v. Paul K. Strasser
Wis. Ct. App. · 2026 · confidence medium
This rule recognizes that extended supervision is a release from prison before the completion of a sentence 4 No. 2023AP1994-CR and thus “is more akin to imprisonment than probation is to imprisonment.” Samson, 547 U.S. at 846, 850, 857 (ruling that a California law that allowed law enforcement officers to search parolees “at any time of the day or night, with or without a search warrant and with or without cause,” did not violate the Fourth Amendment).
discussed Cited as authority (rule) Michael Hester v. Chester Cnty., Tenn. (2×)
6th Cir. · 2025 · confidence medium
Parole, however, confers different rights and expectations than does probation because it is “more akin to imprisonment.” Samson v. California, 547 U.S. 843, 850 (2006).
discussed Cited as authority (rule) Con Lysle Compton v. State of Alaska (2×)
Alaska Ct. App. · 2025 · confidence medium
LaFave, Search and Seizure, § 10.10(d), at 578-88 (6th ed. 2020); see also State v. Fields, 686 P.2d 1379, 1389-90 (Haw. 1984) (requiring reasonable suspicion as a matter of state constitutional law); State v. Velasquez, 672 P.2d 1254, 1260-61 (Utah 1983) (requiring reasonable suspicion); Commonwealth v. LaFrance, 525 N.E.2d 379, 381- 83 (Mass. 1988) (holding that the reasonable suspicion standard protects the public interest while also protecting probationers from unwarranted intrusions into privacy). 58 Samson v. California, 547 U.S. 843, 847 (2006) (concluding that parole conditions author…
discussed Cited as authority (rule) State v. Jenkins (2×)
Ohio Ct. App. · 2025 · confidence medium
Sharp at 753 , citing Samson v. California, 547 U.S. 843, 850-853 (2006); see State v. Currie, 2025- Ohio-670, ¶ 26 (1st Dist.).
examined Cited as authority (rule) Peo v. Mitchell (4×) also: Cited "see"
Colo. Ct. App. · 2025 · confidence medium
Samson, 547 U.S. at 853, 855.
cited Cited as authority (rule) Clarissa Gilmore v. Georgia Department of Corrections
11th Cir. · 2025 · confidence medium
See, e.g., County of Los Angeles v. Mendez, 581 U.S. 420, 427 (2017) (use of force); Samson v. California, 547 U.S. 843, 848 (2006) (search); Florida v. Bostick, 501 U.S. 429, 437 (1991) (seizure).
discussed Cited as authority (rule) Marr v. United States
W.D. Mich. · 2025 · confidence medium
Under this approach, we “assess[ ], on the one hand, the degree to which” the search intruded upon Marr’s privacy “and, on the other, the degree to which [the search was] needed for the promotion of legitimate governmental interests.” Samson v. California, 547 U.S. 843, 848 (2006) (quoting Knights, 534 U.S. at 119 ).
discussed Cited as authority (rule) United States v. Marcus Dixon (2×) also: Cited "see"
7th Cir. · 2025 · confidence medium
The government’s “overwhelming interest” in No. 23-2427 19 supervising parolees and probationers “warrant[s] privacy intrusions that would not otherwise be tolerated under the Fourth Amendment.” Samson, 547 U.S. at 853 (internal quotation marks omitted), quoting Pennsylvania Bd. of Probation and Parole v. Scott, 524 U.S. 357, 365 (1998).
examined Cited as authority (rule) People v. Pyles (6×) also: Cited "see"
Ill. App. Ct. · 2025 · confidence medium
“The touchstone of the Fourth Amendment is reasonableness, and the reasonableness of a search is determined ‘by assessing, on the one hand, the degree to which it intrudes upon an individual’s privacy and, on the other, the degree to which it is needed for the promotion of legitimate governmental interests.’ ” United States v. Knights, 534 U.S. 112, 118-19 (2001) (quoting Wyoming v. Houghton, 526 -6- U.S. 295, 300 (1999)). ¶ 23 The fourth amendment does not categorically prohibit suspicionless parole searches (Samson v. California, 547 U.S. 843, 851, 857 (2006)), but the search must…
discussed Cited as authority (rule) United States v. Robinson
2d Cir. · 2025 · confidence medium
This recognition springs from the principle that the government “interest[] in reducing recidivism and thereby promoting reintegration and positive citizenship . . . warrant[s] privacy intrusions that would not otherwise be tolerated under the Fourth Amendment.” Samson v. California, 547 U.S. 843, 853 (2006). 7 7 Although Samson v. California, 547 U.S. at 857 , concerned suspicionless searches of parolees, we have observed that the diminished Fourth Amendment rights of parolees “appl[y] with equal force to individuals . . . subject to federal supervised release—the reformed successor t…
discussed Cited as authority (rule) Burns v. State of Hawaii
D. Haw. · 2025 · confidence medium
“Under the general Fourth Amendment approach, [courts] assess reasonableness by examining the totality of the circumstances and balancing the intrusion on the individual’s privacy against the promotion of legitimate governmental interests.” Sherman, 502 F.3d at 883 (citing Samson v. California, 547 U.S. 843, 848 (2006)).
Retrieving the full opinion text from the archive…
JAMAL R. SAMPSON
v.
UNITED STATES ERIC T. FRANKLIN v. UNITED STATES
05-9351, 05-9423.
Supreme Court of the United States.
Jun 12, 2006.
547 U.S. 843

The petition for a writ of certiorari is denied.