This Note argues that the Ninth Circuit rigidly followed circuit precedent to create and apply an incorrect standard to determine whether probable cause existed to believe that Howard resided at an unreported address. The court should have determined the reasonableness of the search by balancing Howard\u27s reduced expectation of privacy as a probationer with legitimate governmental interests. Furthermore, the court\u27s analysis served to protect the property at the unreported address rather than Howard\u27s Fourth Amendment privacy rights. This decision is contrary to the principle articulated in Katz v. United States, which states the Fourth Amendment is intended to protect people, not places
