Drug tests, probation, probation officer, search, reasonable suspicion, drug trafficking

Reginald Toney appeals conviction of selling drugs, arguing that evidence against him should have been suppressed. Toney notes that he wasn't notified of a search beforehand and that his probation officer did not have reasonable suspicion to order a search because his positive drug test was 2 1/2-months old at the time of the search.

Mobile Circuit Court convicted Toney of selling drugs and sentenced him to life imprisonment as a habitual offender.

Toney loses; Court of Criminal Appeals of Alabama UPHOLDS conviction, but remands case to circuit court for imposition of a $100,000 fine as mandated by the state in drug trafficking cases. Appeals court rejects Toney's arguments, noting that "failure to receive notice of the methods by which his noncompliance with [his] probation conditions would be detected does not invalidate the search"; and that the probation officer sought an arrest warrant almost immediately after learning of the drug test results. That the test results were delayed did not matter.