Griffin v. Wisconsin
Citation and Court
483 U.S. 868 (1987) — Supreme Court of the United States
Facts
Joseph Griffin was on probation. A Wisconsin regulation permitted probation officers to search a probationer’s home without a warrant as long as a supervisor approved the search and there were “reasonable grounds” to believe contraband was present. A probation officer received a tip and searched Griffin’s home without a warrant, finding a handgun. Griffin challenged the search as requiring a warrant under the Fourth Amendment.
Issue
May a probationer’s home be searched without a warrant, under a state regulation requiring only reasonable grounds and supervisory approval, consistent with the Fourth Amendment?
Holding
Yes; probation supervision constitutes a “special need” that justifies departing from the usual warrant and probable cause requirements when probation officers search a probationer’s home.
Rule / Doctrine
Probationers have a reduced expectation of privacy as a condition of probation. The “special need” of supervising probationers—ensuring they comply with conditions and do not reoffend—is sufficient justification to allow warrantless searches based on reasonable grounds rather than probable cause and a warrant.
Significance
Griffin v. Wisconsin is a key case in the “special needs” doctrine, extending it to the probation context. It is regularly discussed alongside Samson v. California (warrantless searches of parolees permissible on less than reasonable suspicion) to explain the reduced Fourth Amendment protections that attach to those subject to supervision conditions.