In what circumstances will a parole officer be found to have acted without probable cause or consent in search of a person's home?

In support of the argument on illegal search, counsel urges that the parole officer had acted without probable cause, since he did not know the caller and the caller had expressed only a suspicion without supporting data. Counsel also argues that the alleged consent was ineffective as being merely submission to authority. We need not consider either argument. While it has been held that a parole officer must comply with the requirements of section 844 of the Penal Code (except in cases where the law permits forcible entry) (People v. Arellano (1966) 239 Cal.App.2d 389, 48 Cal.Rptr. 686), neither probable cause nor consent are prerequisites for the search by a parole officer of the premises occupied by a parolee. (People v. Hernandez (1964) 229 Cal.App.2d 143, 40 Cal.Rptr. 100.)