Wilson v. Arkansas
514 U.S. 927, 115 S. Ct.
1914, 131 L.Ed.2d 976 (1995)
Author: NetGuru
Facts: The petitioner Wilson sold marijuana to a police informant on different occasions and in one incidence, the petitioner even threatened to kill the informant with a gun if he turned out to be working for the police. The police officers used this evidence to obtain a warrant to search the petitioner's house and arrest the petitioner and her friend. When the officers arrived at Wilson's house, the front door was wide open and the officer opened the unlocked screen door and made an entry while announcing at the same time that they were from the police department and they had a warrant. The petitioner was found in the restroom where she was trying to flush down marijuana and she was arrested. Wilson filed a motion to suppress the evidence based on the claim that the officers did not knock and announce their presence before entering the house. The lower courts rejected the motion and the petitioner was convicted for 32 years in prison. The Supreme Court of Arkansas affirmed the conviction.
Issue: Is the common-law "knock-and-announce" principle part of Fourth Amendment reasonableness inquiry?
Holding: Yes
Reasoning: Justice Thomas: During the construction of the Constitution, the common-law knock and announce rule was well accepted and practiced. So it would be reasonable to assume that the framers considered it to be part of Fourth Amendment for the police officers to knock and ask the suspects to open the door before breaking into the homes of people. According to the court "Given the longstanding common-law endorsement of the practice of announcement, we have little doubt that the Framers of the Fourth Amendment thought that the method of an officer's entry into a dwelling was among the factors to be considered in assessing the reasonaableness of a search or seizure." The court went on to state that this knock and announce principle is not an inflexible requirement which applies to every situation. For example, if a prisoner escapes from jail and hides in his home, the police officers do not have to knock and ask the prisoner to open the door to his house. Also, if there is a risk that evidence will be destroyed if the police knocked and announced, then the officers do not have to follow this rule. Therefore, the court ruled that unless these exigent circumstances exist, the police officers are required to knock and announce their presence before breaking into the houses of suspected criminals.