Arizona Supreme Court
State of Arizona v. Bryan Mitchell Lietzau
May 22, 2020248 Ariz. 576
Summary
The court held that a probation condition requiring warrantless searches of a probationer's person and property encompasses the probationer's cell phone. It further held that the officer's search of Lietzau's phone was reasonable under the totality of the circumstances because it served legitimate probation-supervision purposes and did not exceed the scope reasonably necessary to assess compliance. The court reversed the suppression order, remanded for further proceedings, and vacated the court of appeals' opinion.