People v. Ricardo P. (In Re Ricardo P.), 251 Cal. Rptr. 3d 104

Juvenile Ricardo P. admitted two counts of felony residential burglary and was placed on probation in Alameda County.
Juvenile court imposed drug-related conditions (drug testing, no drug use, no association with drug users) based on Ricardo’s statements about prior marijuana use.
The court also imposed an expansive electronics-search probation condition requiring Ricardo to submit electronic devices and passwords for warrantless searches at any time to monitor compliance with drug conditions.
Ricardo appealed, arguing the electronics-search condition was invalid under the three‑part Lent test and unconstitutionally overbroad.
The Court of Appeal struck the condition as overbroad but upheld it under Lent as reasonably related to supervision; this court granted review limited to Lent’s third prong.
The California Supreme Court held the electronics-search condition invalid under Lent’s third prong because the intrusion on privacy was substantially disproportionate to its asserted purpose on the record before the court, and remanded for further proceedings.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Ricardo)	Held
Whether a warrantless, broad electronics‑search probation condition is "reasonably related to future criminality" under Lent	Condition aids effective supervision of probation, deters drug relapse, and is therefore reasonably related to preventing future criminality	No evidence electronics were used in the offenses or to commit/drug activity; condition disproportionally burdens privacy and thus fails Lent’s third prong	Held: Condition fails Lent’s third prong on this record—burden on privacy substantially disproportionate to rehabilitative/public‑safety interests; condition invalid and remanded

People v. Lent, 15 Cal.3d 481 (establishing three‑part test for probation conditions) (Lent test requires relationship to crime or future criminality)
People v. Olguin, 45 Cal.4th 375 (search/notification conditions can facilitate supervision and thus relate to future criminality)
Riley v. California, 573 U.S. 373 (digital devices contain highly sensitive, comprehensive personal data raising substantial privacy concerns)
People v. Carbajal, 10 Cal.4th 1114 (restitution and probation conditions may be related to deterrence and rehabilitation)
In re Bushman, 1 Cal.3d 767 (invalidating probation condition lacking connection to offense or future criminality)