Does the Fourth Amendment require reasonable suspicion for a probation officer to conduct a warrantless search of a probationer's person or property?

QUESTIONS PRESENTED Bryan Lietzau was arrested for administrative violations of his probation, and a surveillance officer searched his cellular phone because, as he put it, he does not need a warrant and he “go[es] through hundreds of phones a month.” The Arizona Supreme Court determined that Riley v. California, 573 U.S. 373 (2014), has no bearing on the question of cell phone searches of probationers. In so doing, it deepened a split of authority on two issues. The questions presented are: Does the Fourth Amendment require reasonable suspicion for a probation officer to conduct a warrantless search of a probationer’s person or property? Does the Fourth Amendment prohibit suspicionless and comprehensive searches of a probationer’s cell phone absent standards for ensuring that such searches are not arbitrary? 1