Snapchat APP on a phone.

A California appeals court continued to chisel out the circumstances in which courts can impose warrantless electronic device searches as a condition of probation, after a juvenile was ordered to hand over access to her texts and social media accounts for dragging a classmate down a staircase and stomping her face.

On Friday, the First District Court of Appeal reversed and remanded a ruling from Contra Costa Superior Court requiring Amber K. to submit her electronic devices for searches to ensure she is complying with all the terms of her probation, including cutting off all communication with the girl she assaulted, who is referred to as B. in the opinion.

On appeal, Amber contested the judge's order that she must hand over access to her texts, voicemails, photos, emails and other social media apps such as Snapchat, Instagram, Facebook and Kik. Amber's attorney Kevin Lindsley of The Law Office of Kevin J. Lindsley in Pleasanton, California, argued that the probation condition was unconstitutional and not properly tailored, according to the opinion.

State prosecutors pegged the probation condition to how classmates filmed the assault and posted it to Snapchat, but the First District said the Attorney General's Office did not present evidence that Amber arranged for the filming and distribution of the fight.

The court punted on the constitutional questions, but agreed with Lindsley that the searches did not meet the standard created by the 1975 People v. Lent decision, which requires probation conditions to relate to the crime at hand, criminal behavior and future criminality.

"We agree with Amber that the record does not show a relationship between her use of electronic devices and the offending conduct sufficient to justify the electronic search condition under the first prong of Lent," wrote Associate Justice Marla Miller on behalf of Acting Presiding Justice James Richman and Associate Justice Therese Stewart. "Although the record suggests that the assault resulted from hostility between Amber and B. that had played out in part over social media, we are not persuaded by the attorney general's contention that 'substantial evidence in the record connects appellant's use of electronic devices and social media to the assault.'"

The decision comes after California's Sixth District Court of Appeal ruled that warrantless electronic device searches as part of a probation for a high-school-aged boy, who used cell phone videos and photos to extort a former juvenile sexual partner for money and sexual favors for a friend, were constitutional and narrowly tailored since his electronic devices were a key component of his crimes.

Both the First District and Sixth District's opinions cite In re Ricardo P., an August ruling that  found warrantless searches of 17-year-old Ricardo P.'s devices overbroad, since his use of electronic devices was not integral to his decision to burglarize.

The First District said that an electronic search provision is appropriate, but in light of Ricardo P., ruled that the condition was not proportionate.

"Although the court tailored the condition by identifying examples of the types of communication subject to search, the condition was broadly worded to cover media 'reasonably likely to reveal whether she is complying with the terms of her probation,' not limited to the term that Amber have no contact with B.," Miller wrote.