In re Tyrell J. examines the parameters of warrantless searches of juvenile probationers. In Tyrell, the California Supreme Court limited the use of the exclusionary rule as applied to unconstitutional searches. This note will discuss the history of the exclusionary rule and the probation search exceptions. The note will then examine the court's reasoning in Tyrell. The note will conclude by contending that the Tyrell majority disregarded the constitutional protections afforded adult citizens, and in effect reinterpreted the United States Supreme Court's "reasonableness standards."
In re Tyrell J.: Children and Their Reasonable Expectations of Privacy, 25 Golden Gate U. L. Rev.