Last month, in United States v. Braggs, — F.4th —, 2021 WL 2931403 (2d Cir. July 13, 2021), the U.S. Court of Appeals for the Second Circuit clarified the applicable standards governing the Fourth Amendment rights of parolees. In a unanimous opinion written by Judge Richard C. Wesley, and joined by Judge Robert D. Sack and Judge Steven J. Menashi, the Second Circuit held that parole officers' searches of parolees are governed by the "special needs" exception to the Fourth Amendment's default requirement that a law enforcement-related search be conducted pursuant to a showing of probable cause and a warrant. Thus, the government must show that a parole officer's search of a parolee was rationally and reasonably related to the parole officer's duties.