The People v. Ermi

Opinion

YEGAN, J.

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,…