State of Tennessee v. Janet Michelle Stanfield, Tony Alan Winsett, and Justin Bradley Stanfield, W2015-02503-CCA-R3-CD

Officers from a drug task force conducted a purported parole/probation check at 3089 Shady Grove Road after a confidential tip that parolee Tony Winsett was using/injecting meth; officers found plastic bags with marijuana residue in a nearby burn pile and observed an open window and lights.
Officers forced entry without a warrant after knocking, smelled marijuana inside, encountered a dog, and then searched three bedrooms; they found methamphetamine, two handguns, ammunition, drug paraphernalia, and about seven ounces of marijuana in Justin Stanfield’s room.
Justin was stopped after officers viewed a vehicle on the house’s security monitor; he later admitted selling marijuana and consented to unlock his phone; a separate arrest and vehicle detention of Janet and Winsett produced alprazolam pills in Janet’s purse.
Defendants moved to suppress evidence; the trial court granted suppression and dismissed the indictment, finding that after the house was secured the officers should have obtained a warrant and no exigent circumstances persisted.
The State appealed, arguing the searches were lawful because Winsett was a parolee and Janet a probationer (each with search conditions), and because of alleged common authority over shared areas.

Issue	Plaintiff's Argument (State)	Defendant's Argument	Held
Lawfulness of warrantless search of Winsett’s residence (parolee)	Parolee’s warrantless-search condition permits suspicionless entry; totality supports search	Search was unreasonable once officers cleared the house; parole condition didn’t justify continuing intrusion	Search unreasonable; suppression affirmed
Lawfulness of warrantless search of Janet’s residence/areas (probationer)	Probation agreement and cohabitation with parolee justify search; reasonable suspicion existed	Probation condition is narrower (requires request; limited to contraband/stolen property) and officers were unaware of her status	No reasonable suspicion; probation agreement did not authorize the search; suppression affirmed
Validity of evidence seized from Janet following later traffic stop and seizure	Evidence from later stop/search is independent/incident to arrest	Stop and seizure were tainted by the unlawful house search and thus attenuated	Stop and seizure were attenuated from unlawful search; evidence suppressed
Validity of search in Justin’s bedroom based on common authority	Cohabitation and open bedroom door indicate common authority to consent	Open door alone insufficient; bedrooms treated as separate private spaces	No common authority shown; suppression affirmed

State v. Turner, 297 S.W.3d 155 (Tenn. 2009) (parolee warrantless-search condition requires totality-of-circumstances reasonableness review)
Samson v. California, 547 U.S. 843 (U.S. 2006) (parolees may be subject to suspicionless searches; courts examine reasonableness under the Fourth Amendment)
United States v. Knights, 534 U.S. 112 (U.S. 2001) (probation condition consenting to search is valid but requires reasonable suspicion for constitutionality)
United States v. Matlock, 415 U.S. 164 (U.S. 1974) (third-party consent requires common authority via mutual use/joint access)
State v. Yeargan, 958 S.W.2d 626 (Tenn. 1997) (warrantless searches are presumptively unreasonable; State bears burden to justify exceptions)