Monzulla

MEMORANDUM **

1. Monzulla challenges the search of his vehicle because the probation officer had no “personal knowledge” when he requested the search. But United States v. Knights, 534 U.S. 112, 122 , 122 S.Ct. 587 , 151 L.Ed.2d 497 (2001), only requires that a “warrantless search of [an individual on probation be] supported by reasonable suspicion and authorized by a condition of probation.... ” And reasonable suspicion is “a lesser than probable-cause standard.” Id. at 121 , 122 S.Ct. 587 .

The probation officer had ample reasonable suspicion here: A state trooper reported that Monzulla had admitted to carrying a loaded firearm in his vehicle, in violation of his probation conditions; and Monzulla’s probation conditions explicitly allowed for warrantless, nonconsensual searches for alcohol, controlled substances and prohibited firearms. That the probation officer did not hear the admission himself is of no consequence. See United States v. Stokes, 292 F.3d 964, 967-68 (9th Cir.2002) (holding that “reasonable suspicion was clearly met” where a probation officer searched a probationer’s car based on a police officer’s report that another man accused the probationer of stealing…