Wilson v. Arkansas Case Brief: The Fourth Amendment and the Knock-and-Announce Rule

Case Brief: Wilson v. Arkansas

Court: Supreme Court of the United States
Citation: 514 U.S. 927 (1995)
Decided: May 22, 1995

Facts:

Sharlene Wilson sold illicit narcotics to an informant working with law enforcement. Based on this transaction, the police obtained a search warrant for Wilson's home. Upon arriving at Wilson's residence, the officers did not announce their presence or purpose before entering. They found evidence of drugs and firearms, leading to Wilson's conviction for delivery of marijuana, methamphetamine, and drug paraphernalia, as well as possession of drug paraphernalia. Wilson appealed, arguing that the evidence should have been suppressed because the officers failed to "knock and announce" before entering.

Issue:

Does the Fourth Amendment require police officers to knock and announce their presence before entering a dwelling to execute a search warrant?

Holding:

Yes, the Fourth Amendment does require that police officers knock and announce their presence before entering a dwelling to execute a search warrant, unless there are specific circumstances that justify an unannounced entry.

Legal Reasoning:

• Common Law Background: The Court acknowledged the common law principle requiring officers to knock and announce their presence before entering a home. This principle was part of the reasonableness requirement of the Fourth Amendment.
• Fourth Amendment: The Court emphasized that the Fourth Amendment's requirement of reasonableness in searches and seizures should incorporate the knock-and-announce rule, drawing on historical precedents and common law practices.
• Exceptions to the Rule: The Court also noted that the knock-and-announce requirement is not absolute. It allows exceptions when there is a reasonable suspicion that knocking and announcing would be dangerous, futile, or inhibit the effective investigation of the crime (e.g., allowing the destruction of evidence).

Conclusion:

The Supreme Court held that the Fourth Amendment does encompass the knock-and-announce principle. The case was remanded for further proceedings to determine whether the unannounced entry in Wilson's case was justified under the exceptions to the rule.

List of Cases Cited

1. Miller v. United States, 357 U.S. 301 (1958) - Affirmed the common law principle that officers must announce their presence and purpose before forcibly entering a residence.
2. Ker v. California, 374 U.S. 23 (1963) - Allowed for certain exceptions to the knock-and-announce requirement based on the circumstances.

Similar Cases

1. Hudson v. Michigan, 547 U.S. 586 (2006) - Held that a violation of the knock-and-announce rule does not necessarily require the suppression of evidence found in the subsequent search.
2. Richards v. Wisconsin, 520 U.S. 385 (1997) - Ruled that police officers are not required to knock and announce when they have reasonable suspicion that doing so would be dangerous, futile, or result in the destruction of evidence.