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Sanchez v. City of San Diego

464 F.3d 916 (2006)

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Sanchez v. City of San Diego

United States Court of Appeals for the Ninth Circuit
464 F.3d 916 (2006)

  • Written by Robert Cane, JD

Facts

The San Diego County (defendant) program Project 100% required welfare applicants to consent to home visits as a condition of eligibility for benefits. Each applicant was subject to an interview and a walk-through of his or her home. The visits were conducted by sworn peace officers from the district attorney’s office with advance notice provided to applicants. The walk-through included potential requests by the officers to view the contents of closets and cabinets. The peace officers were obligated to report any evidence of potential criminal wrongdoing in plain view. The applicants were free to refuse the home visits without penalty except for the denial of benefits. The purpose of the visits was to confirm applicants were eligible for the welfare program. No criminal prosecutions have resulted from a Project 100% home visit. San Diego County welfare applicants (plaintiffs) challenged the home-visit requirement as a violation of the Fourth Amendment’s protection against unreasonable searches, among other reasons. The district court found the searches to be reasonable. The welfare applicants appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Tashima, J.)

Dissent (Fisher, J.)

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