The Case of United States v. Knights

Abstract

The Fourth Amendment bans unreasonable searches and seizures. Additionally, its Warrant Clause sets the fundamental requirements for the search warrants that must be reinforced by a signed affidavit that outlines probable cause. The purpose of this paper is to synthesize the Case of United States v. Knights in order to have a good understanding of the provisions of the Fourth Amendment with regards to warrants and probable cause. The Warrant Clause is one of the most comprehensible clauses of the United States Constitution. It demands that warrants are reinforced by probable cause. That implies that a law enforcement agent seeking the warrant must swear an oath to support the application, and that the warrant outlines the location of the search and what the officer is allowed to search and seizure. However, the Warrant Clause fails to clearly depict the meaning of probable cause and all the circumstances that officers are required to obtain in search warrants. The Case of United States v. Knights is an apt example of a classic case that needed the interpretation of the Fourth Amendment under probationary and investigative circumstances.

Forensic evidence must be admissible at a trial to be applicable in the prosecution of a criminal (Karagiozis & Sgaglio, 2005). In other words, insufficient amount of credible evidence hurdles the prosecution’s case or lead to its dismissal. Therefore, it is vital for an investigator to ensure that the presented evidence is authentic and was collected under a legal search and seizure to overcome suppression of evidence. In this line, this paper explores the case of the United Stated v. Knights that challenged the warrants and probable cause clauses of the Fourth Amendment.

Issue

Mark Knights had been sentenced to the probation on drug charge. In line with the terms of the probation as signed and agreed by the defendant, Knights consented to warrant or warrantless searches of his property, residence, personal effect, and vehicle by a probation officer and any other law enforcement agent (United States v. Knights, 2001). Following a close observation of the respondent, his movements and activities prompted him to become a suspect in a number of vandalism acts against Pacific Gas & Electric (PG&E). For example, the surveillance of the two suspects noted that Simoneau, the respondent’s friend, had dropped what was understood to be pipe-based explosives into the Napa River. Consequently, explosive materials and other solid evidence connecting the suspect to the crimes against PG&E were found in Simoneau’s truck. With the knowledge about the terms of the suspect’s probation, Detective Hancock conducted a search in Knights’ house and found more explosive-making materials, drug paraphernalia, bolt cutter, instruction manuals on electrical circuity and chemistry, a detonation cord, and brass padlock with the PG&E brand. Knights contested that his right to privacy provided by the Fourth Amendment was denied because the search and seizure were conducted for investigatory purposes instead of probationary aims. In other words, the underlying issue was whether the provisions of the Fourth Amendment limit searches and seizures pursuant to a probation condition.

Rule

The Supreme Court dismissed the argument that the search and seizure should have been conducted by a probation officer mandated to monitor whether Knight (probationer) was complying with the terms of the probation (United States v. Knights, 2001). The dismissal was based on the reasonableness and a fact that it is the government’s interest to apprehend any violators of the United States criminal law; hence, protecting any potential victims of criminal activities. In that regard, a probation officer or a law enforcement agent is justified to conduct searches, seizures and arrests as long as there is probable cause. The respondent conceded that the search and seizure were reinforced by reasonable suspicion. This ruling was in line with the provisions of the Fourth Amendment discussed in detail in the following section.

Analysis

The case involved the Fourth Amendment to the U.S. Constitution that provides the right of United States citizens to secure against unreasonable searches and seizures. Furthermore, Warrant must only be issued upon probable cause reinforced by affirmation or Oath. Additionally, the warrant must describe search location, the things and persons to be seized (Solove, 2010). Knight was living under probationary provisions that permitted a search and seizure against him with or without a warrant. Under observation by a detective, the respondent and his friend became main suspects in a vandalism spree against (PG&E) company. Following subjective conclusion that the two were responsible for the vandalism crimes against the company, the detective searched and arrested the respondent after finding incriminating evidence against the suspect.

Inherent in the aspects of probation, probationers have limited rights compared to other citizens (Markham, 2010). Considering the revelation of a significant amount of evidence connecting the respondent to the crimes committed against PG&E, he was arrested and indicted for possession of undisclosed destructive device, conspiracy to commit arson, and being an offender in possession of ammunition. Regardless of the fact that there were attempts to suppress the evidence found in the process of the search, the District Court held that there was reasonable suspicion for the detective to believe that the respondent was involved with inflammable material. However, the District Court granted motion to suppress the evidence on the rationale that the search and seizure were investigatory as opposed to probationary reasons.

In agreement with the Supreme Court’s perspective, it is crucial to deliver reasonable rulings that reject a similar distinction contested by Knight. In fact, the probation order had included the condition that Knights’ property and residence would be searched at any time with a probable cause by any law enforcement agent or probation officer. Consenting to the terms, Knights signed the probation order that claimed that he had read and understood all the terms and conditions, and agreed to abide by the same (United States v. Knights, 2001). Certainly, there was term in the probation order that accentuated that Knights was confined to only probationary searched. The point is that the probation order provides is that Knights was subject to search by any law enforcement agent. The question was whether searches pursuant to probation condition was limited by the Fourth Amendment.

In assessing the constitutionality of the search and seizure of evidence at the respondent’s residence, it is vital to point that the United States interest is to ensure that all citizens are protected from criminal activities that Knights and his accomplice were committing against the PG&E. Additionally, Knights’ acceptance of the conditions in the probation order were voluntary because he could have challenged them by demanding clarification or not signing it completely. Arguably, by choosing not to go to jail and singing the probation order, Knights had submitted to abide by all the conditions including warrantless search and arrest with reasonable cause. Analogously to the voluntary decision, Knights had agreed to waive some of his constitutional liberties enjoyed by free law abiding citizens. The central pillar of the Supreme Court’s ruling in reasonableness was determined by establishing the degree to which Knights privacy was intruded, and the promotion of legitimate government interests. Logically, the government’s interest to protect citizens is justified. Additionally, Knights privacy was not intruded as he had agreed to be searched at any time for both probationary and investigatory reasons. To recap, the search by Detective Hancock pursuant to Knights probation condition, and reinforced by reasonable suspicion (probable cause) satisfied the provision of the Warrant Clause and Probable Cause as outlined in the Fourth Amendment.

Conclusion

In all criminal investigation and prosecutions, it is significant to overcome the question of whether an investigator collected incriminating evidence through a legal search and seizure. In line with the ruling of case of United States v. Knight, it essential for an investigators to have a probable cause in conducting searches and seizures, especially where the collection of incriminating evidence may conflict with the provision of the Fourth Amendment. The Fourth Amendment bans the government from unreasonable searches and seizures in the name of collecting evidence against a suspect. In the above case, the defendant’s privacy was limited after signing the probation form. In summary, inherent in all aspects of probation, a probationer does not possess the absolute liberty to which United Stated citizens are entitled. Therefore, law enforcement agents are justified to execute searches and seizures to collect admissible evidence against individuals under probation for investigative purposes as long as there is probable cause.