In Samson v. California, the Court considered the constitutionality of a state statute providing that upon release on state parole, the inmate "shall agree in writing to be subject to search or seizure by a parole officer or other peace officer at any time of the day or night, with or without a search warrant and with or without cause." In this case, Samson was stopped on the street by a police office, a suspicionless search was conducted, and drugs were discovered. At trial, Samson moved to suppress the evidence, but his motion was denied.
In determining whether the search violated the Fourth Amendment, SCOTUS applied a totality of the circumstances test. In balancing the liberty interest versus the state's interests, the Court noted that the "ability to conduct suspicionless searches of parolees serves [the state's] interest in reducing recidivism, in a manner that aids, rather than hinders, the reintegration of parolees into productive society." The fact that a parolee is still under much state supervision and restrictions coupled with the state's interest in reducing recidivism, persuaded the Court that the statute did not violate the Fourth Amendment.