Ermi

A probationer may devise a method to hide illicit drugs. “Search terms” allow a peace officer to search any area over which the probationer has control or access. Here, a probationer’s girlfriend, appellant, lives with him in an apartment. We conclude that his girlfriend’s purse, which was on a chair in their bedroom, was subject to search because this is a repository over which the probationer has control or access. A probationer has no entitlement to Fourth Amendment protections because of ingenuity in selecting a hiding place for drugs.

Facts

On the evening of August 1, 2011, Oxnard Police Officer Paul Knapp knocked on Ronald Williams’s apartment door to conduct a probation search. Williams was on probation with “search terms.” Appellant, Williams’s girlfriend, answered the door and summoned Williams. He emerged from the bedroom and greeted Officer Knapp. Appellant said that she, Williams, and their son shared the bedroom.

Officer Knapp entered the cluttered bedroom and saw a lot of bags, boxes, and things strewn about. A tan purse was on a chair in the middle of the room. Officer Knapp picked it up. Appellant said it was her purse and that she needed medication out…