C.A. 4th;
D070732

The Fourth Appellate District affirmed a judgment. The court held that a probationer's warrantless search condition included within its scope the contents of the probationer's cell phone.

After confirming that Megan Sandee was on probation and subject to a search condition, a detective searched her belongings, including her cell phone. He discovered several text messages that he believed were indications that Sandee was involved in selling narcotics. The detective took photos of the text messages and noted them in his report. Sandee was later charged with multiple narcotics offenses. After the trial court denied her motion to suppress, Sandee pleaded guilty to possession for sale of a controlled substance and unauthorized possession of a controlled substance.