IN LATTA, THE COURT UTILIZING THE FOURTH AMENDMENT TEST OF REASONABLENESS AND ANALOGIZING PAROLE INSPECTION SEARCHES TO ADMINISTRATIVE SEARCHES NOT REQUIRING WARRANTS, UPHELD THE REVOCATION OF THE DEFENDANT'S PAROLE AND SUBSEQUENT CONVICTION ON A DRUG POSSESSION CHARGE, BASED ON EVIDENCE OBTAINED FROM A WARRANTLESS PAROLE OFFICER SEARCH. IN CONSUELO-GONZALEZ, WHERE THE DEFENDANT WAS ON PROBATION, THE COURT HELD THAT A SEARCH BY LAW ENFORCEMENT OFFICERS WAS UNREASONABLE AND THAT THE EVIDENCE SEIZED AS A RESULT SHOULD HAVE BEEN SUPPRESSED BY THE TRIAL COURT BOTH DECISIONS WERE BASED ON A RECOGNITION AND BALANCING THE PROBATION/PAROLE OFFICER'S SPECIAL SUPERVISORY AND VISITATION POWERS (WHICH, IT WAS HELD, DID NOT EXTEND TO LAW ENFORCEMENT OFFICERS) AND THE PAROLEE'S/PROBATIONER'S RIGHT TO PROTECT HIS PERSONAL PRIVACY. THE AUTHOR MAINTAINS THAT THE BLURRING OF PAROLE/PROBATION OFFICER AND POLICE OFFICER ROLES MAKES THE PAROLE/PROBATION OFFICER'S SEARCH DUTIES SEEM MORE PUNITIVE AND LESS RECONSTRUCTIVE AND CAN NEITHER ENCOURAGE POSITIVE BEHAVIOR IN THE PAROLEE/PROBATIONER NOR FURTHER HIS RELATIONSHIP WITH HIS PAROLE/PROBATION OFFICER. SHE SUGGESTS THAT BEFORE THERE CAN BE AGREEMENT ON WHAT IS REASONABLE IN ANY PAROLE/PROBATION SEARCH, THERE MUST BE AGREEMENT ON THE ROLE OF THE PROBATION/ PAROLE OFFICER AND CLARIFICATION OF THE NATURE OF THE SPECIAL RELATIONSHIP BETWEEN THAT OFFICER AND THE PAROLEE/PROBATIONER. (AUTHOR ABSTRACT MODIFIED)