State v. Cornwell, 412 P.3d 1265

Curtis Cornwell was on probation with a written condition consenting to searches of his person, residence, automobile, or property upon reasonable cause that he violated probation.
Cornwell had an outstanding DOC warrant for failure to report; officers located him driving a Chevrolet Monte Carlo tied to a suspected drug house.
Cornwell fled when ordered out of the vehicle and was arrested; officers found $1,573 on his person.
A community corrections officer (CCO) searched the Monte Carlo without a warrant and seized drugs, drug paraphernalia, SIM cards, and a cell phone from a bag on the front seat.
Cornwell moved to suppress; the trial court denied the motion, a jury convicted him, and the Court of Appeals affirmed. The Washington Supreme Court granted review on the lawfulness of the property search.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Cornwell)	Held
Whether a warrantless property search by a CCO must be limited by a nexus between the property searched and the suspected probation violation	Probationers have reduced privacy and thus any property may be searched when a CCO has reasonable cause to believe a probation violation occurred	RCW 9.94A.631 and article I, §7 require a nexus: the searched property must be reasonably linked to the suspected violation	The Washington Constitution requires a nexus; searches must be reasonably related to the suspected probation violation
Whether the search of Cornwell’s vehicle was lawful	The search was authorized because Cornwell had a DOC warrant and was driving the vehicle	There was no reason to believe the vehicle would contain evidence of the only supported violation (failure to report)	The vehicle search lacked the required nexus and was unlawful; seized evidence should have been suppressed

State v. Olsen, 189 Wash.2d 118 (Wash. 2017) (probationers have a reduced expectation of privacy; supervision must be reasonably tailored)
State v. Winterstein, 167 Wash.2d 620 (Wash. 2009) (CCO may search on well-founded or reasonable suspicion of probation violation)
State v. Patton, 167 Wash.2d 379 (Wash. 2009) (no nexus exists between property and the offense of failure to report)
State v. Ladson, 138 Wash.2d 343 (Wash. 1999) (warrant requirement subject to few carefully drawn exceptions)
State v. Ibarra-Cisneros, 172 Wash.2d 880 (Wash. 2011) (exclusionary rule applies to unlawfully obtained evidence)
Griffin v. Wisconsin, 483 U.S. 868 (U.S. 1987) (probation is a form of state supervision justifying closer scrutiny of probationers)