a special needs case that essentially used the special needs doctrine to reach the result reached by Samson. See McCullough, 6 P.3d at 780-81. Likewise, Sullivan did not analyze the facts of the case for anything resembling voluntariness. See 975 N.E.2d at 1001. Neither did its jurisprudential progenitor, Benton. See 695 N.E.2d at 761. Rather, Benton simply concluded parolees may be subjected to suspicionless searches based on policy grounds largely related to the parolee’s status. See id. Our rejection of Samson in Ochoa leads us to reject these cases as well. See 792 N.W.2d at 287-91. Additionally, two cases pique our concern that suspicionless consent searches of parolees also impact persons who live with parolees. See McFerrin v. State, 344 Ark. 671, 42 S.W.3d 529, 534-35 (2001) (<HOLDING>); Devore, 2 P.3d at 156-57 & nn. 1, 2 (holding
holding that a parole condition which restricted a parolees access to the internet unless he had prior approval of his parole officer was reasonably related to reintegrating the parolee into his community and protecting the general public and did not violate parolees first amendment rights holding suspicionless searches of parolees cannot be justified by consent if prospective parolee does not have freedom to accept or reject parole holding parole officer could extract consent from parolees sister prior to parolees release holding requirement that a prisoner agree to search condition of parole is reasonable in light of the parolees significantly diminished privacy interests holding warrantless search of common areas of parolees apartment which he shared with his mother was lawful even though parolees mother may not have consented to the search