State of Tennessee v. Angela Carrie Payton Hamm and David Lee Hamm

The Obion County Drug Task Force conducted a warrantless search of the residence of probationer Angela Hamm and her husband, David Hamm, which yielded illegal drugs and drug-related contraband.  Defendant Angela Hamm had agreed, pursuant to probation conditions imposed in a prior case, to a warrantless search of her person, property, or vehicle at any time.  We granted the State’s appeal in this case to consider whether the warrantless search of a probationer’s residence who is subject to a search condition requires officers to have reasonable suspicion of illegal activity prior to conducting the search.  We conclude that it does not and therefore reverse the trial court’s judgment and the Court of Criminal Appeals’ decision affirming the same.