Is a probation officer permitted to search a defendant's electronic search device while they were in a sexual relationship?

Nothing in the record suggests any electronic device played a role in defendant's current offense, and communicating electronically is not in itself criminal. But the electronic search condition is reasonably related to preventing future criminality. Defendant is subject to a criminal protective order and a probation condition prohibiting her from contacting the victim in any way, including electronically. The sexual nature of their relationship suggested they might attempt to contact each other to maintain their relationship. Even if there was no evidence that defendant had used an electronic device to contact the victim, it was not unreasonable to believe she might attempt to do so in the future. The electronic search condition enables the probation officer to monitor defendant's compliance with the protective order and her probation conditions. Accordingly, the electronic search condition was reasonable under the circumstances, and the trial court did not abuse its discretion in imposing it. (See People v. Ebertowski (2014) 228 Cal.App.4th 1170, 1176-1177 [finding a similar electronic search condition

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reasonably related to future criminality because it enabled probation officer to monitor the defendant's gang associations and activities].)⁴