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.