Law School Case Brief
Hudson v. Michigan - 547 U.S. 586, 126 S. Ct. 2159 (2006)
Rule:
Suppression of evidence has always been the United States Supreme Court's last resort, not the Supreme Court's first impulse. The exclusionary rule generates "substantial social costs," which sometimes include setting the guilty free and the dangerous at large. The Supreme Court has rejected "indiscriminate application" of the rule and has held it to be applicable only where its remedial objectives are thought most efficaciously served--that is, where its deterrence benefits outweigh its "substantial social costs."
Facts:
When police arrived to execute a search warrant for drugs and firearms at defendant's home, they announced their presence but waited only a short time before turning the knob of the unlocked front door and entering the home. Police discovered large quantities of drugs and a loaded gun. The State conceded that the entry was a violation of the "knock and announce" rule. The state trial court granted defendant's motion to suppress; however, the Michigan Court of Appeals reversed this decision, finding that violation of the "knock and announce" rule did not require suppression under the Fourth Amendment. Consequently, defendant was convicted of drug possession.
Issue:
Does the violation of “knock and announce” rule require suppression of evidence under the Fourth Amendment?
Answer:
No.
conclusion:
The Court determined that the exclusionary rule was inapplicable and suppression of the evidence was not warranted because violation of the "knock-and-announce" rule did not require the suppression of all evidence found in the search. Moreover, the Court held that the constitutional violation of an illegal manner of entry was not a but-for cause of obtaining the evidence. The Court also noted that the interests that were violated, preventing the Government from seeing or taking evidence described in a warrant, had nothing to do with the seizure of the evidence. In conclusion, the Court ruled that the social costs of applying the exclusionary rule to knock-and-announce violations were considerable, the incentive for such violations was minimal to begin with, and the extant deterrence against them were substantial. As such, the Court affirmed the judgment of the state appellate court.