The “special needs” rationale discussed in this chapter has routinely been used by courts to justify searches based only on rea¬

sonable suspicion of persons on probation or parole. In Coleman v. Commonwealth [100 S.W.3d 745 (2003)], the Kentucky Supreme Court refused to justify the search by a parole officer of the parolee’s residence. The conditions of the defendant’s parole included his permission to search his residence with¬

out any necessary suspicion. What effect on the court’s decision did this provision have?

Would the Supreme Court decision in Sam¬

son v. California (discussed previously) have changed the result?