The following excerpt is from Vaccaro v. Henry, 105 F.3d 668 (9th Cir. 1996):
A probation officer acts as a stalking horse for law enforcement agents if he conducts a probation search at the request of and in conjunction with police officers, thereby enabling the officers to bypass the Fourth Amendment search warrant and probable cause requirements. United States v. Vought, 69 F.3d 1498, 1501 (9th Cir.1995); United States v. Watts, 67 F.3d 790, 794 (9th Cir.1995), cert. denied, 116 S.Ct. 1369 (1996). We review for clear error whether a probation officer was a stalking horse. Vought, 69 F.3d at 1501; Watts, 67 F.3d at 794.
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