Pendleton v. State

STEELE, Chief Justice:

In this appeal, we consider the validity of evidence seized during an administrative search conducted after a probation officer telephonically conferred with his supervisor but failed to complete a tangible, paper copy of a pre-search checklist. Ezra Pen-dleton contends that absent exigent circumstances, probation officers should strictly comply with the Department of Corrections’ guidelines and failure to do so here necessitates a reversal of his Possession with intent to Deliver Cocaine convic tion. In Fuller v. State, 1 we acknowledged that substantial compliance with…