United States v. Braggs, 5 F.4th 183

Braggs was on DOCCS parole with conditions including a curfew, prohibition on firearms, and a signed consent to parole searches of person/residence.
DOCCS Directive No. 9404 permits warrantless parole searches only where there is an "articulable reason"—defined by the directive in terms similar to reasonable suspicion.
DOCCS received an anonymous tip that Braggs might have guns; parole officers (after supervisory approval) searched his home, handcuffed him for safety, and seized firearms, ammunition, drugs, paraphernalia, and cash.
Local police arrived after the seizure, Mirandized Braggs, and obtained inculpatory statements; federal charges followed and Braggs moved to suppress the evidence.
The district court credited the officers but suppressed, reasoning the search lacked reasonable suspicion under DOCCS Directive No. 9404 and distinguishing Samson; the Government appealed.
The Second Circuit vacated the suppression order, holding federal law controls exclusionary analysis and, under the Special Needs doctrine, parole officers may search when reasonably related to parole duties—here, investigation of an alleged firearm possession.

Issue	Braggs' Argument	Government's Argument	Held
Whether state DOCCS directive ("articulable reason") sets exclusionary-rule standard in federal prosecution	District court may apply DOCCS reasonable-suspicion requirement; directive controls	Federal law governs Fourth Amendment analysis in federal prosecutions	Federal law governs; district court erred to adopt DOCCS directive as exclusionary standard
Whether Samson (suspicionless search of parolee by law enforcement) controls here	Samson distinguishable because search was by parole officers, not police	Samson and diminished expectation of privacy could justify the search	Samson inapplicable to searches by parole officers; distinction matters
Proper standard for parole-officer searches (Special Needs v. reasonable suspicion)	Braggs: reasonable suspicion required for parole-officer searches under NY policy	Government: Special Needs standard applies; search permissible if reasonably related to parole duties	Special Needs applies: parole-officer searches are lawful if reasonably related to supervision/investigation duties
Whether the search here was constitutional	Tip alone insufficient under reasonable-suspicion framing	Anonymous tip alleging firearms constituted information that justified a parole search under Special Needs	Search was reasonably related to parole duties given tip re: firearms; suppression vacated

Samson v. California, 547 U.S. 843 (suspicionless search of parolee by police upheld based on parole consent and diminished privacy)
Knights v. United States, 534 U.S. 112 (probation search upheld on reasonable suspicion; left open scope for parole searches)
Griffin v. Wisconsin, 483 U.S. 868 (state probation/parole systems present "special needs" that can relax warrant/probable-cause rules)
Preston v. United States, 376 U.S. 364 (federal courts judge searches by state officers under federal Fourth Amendment standards)
United States v. Pforzheimer, 826 F.2d 200 (evidence admissible under federal law cannot be excluded because inadmissible under state law)
United States v. Grimes, 225 F.3d 254 (Second Circuit: parole searches permissible if reasonably related to parole duties)
United States v. Barner, 666 F.3d 79 (parole search justified where officer received information of parole/criminal violations and had duty to investigate)
United States v. Newton, 369 F.3d 659 (parole officers reasonably searched after information that parolee had a gun and threatened others)
United States v. Freeman, 479 F.3d 743 (distinguishing Special Needs parole-officer searches from Samson/Knights line applying to general law enforcement)
Hensley v. United States, 941 F.3d 646 (state-law context can inform expectation of privacy but does not set federal exclusionary rule)
Ferguson v. City of Charleston, 532 U.S. 67 (discusses law-enforcement interests distinct from special governmental needs)