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Law School Case Brief

Wilson v. Arkansas - 514 U.S. 927, 115 S. Ct. 1914 (1995)

Rule:

The Fourth Amendment of the Constitution protects the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures. In evaluating the scope of this right, the court has looked to the traditional protections against unreasonable searches and seizures afforded by the common law at the time of the framing. Although the underlying command of the Fourth Amendment is always that searches and seizures be reasonable, the content of this term may be guided by the meaning ascribed to it by the framers of the Amendment. An examination of the common law of search and seizure leaves no doubt that the reasonableness of a search of a dwelling may depend in part on whether law enforcement officers announced their presence and authority prior to entering.

Facts:

While executing search and arrest warrants, police officers found the main door to Sharlene Wilson’s home open. While opening an unlocked screen door and entering the home, the officers identified themselves as police officers and stated that they had a warrant. Once inside, the officers seized various narcotics and narcotics paraphernalia and arrested Wilson. In a pretrial motion to suppress the evidence, Wilson asserted that the search was invalid on various grounds, including that the police officers had failed to "knock and announce" before entering Wilson’s home. The motion to suppress was denied, and the accused was convicted in an Arkansas state court of several narcotics offenses. The Arkansas Supreme Court affirmed, rejecting Wilson’s argument that the Federal Constitution's Fourth Amendment required the officers to knock and announce their presence prior to entering the residence, and concluded that neither Arkansas law nor the Fourth Amendment required suppression of the evidence. Wilson sought certiorari review.

Issue:

Does the U.S. Const. amend. IV require police officers to knock and announce themselves before entering a residence when executing a search warrant?

Answer:

Yes

Conclusion:

The United States Supreme Court reversed, holding that the common-law knock and announce principle formed a part of the Fourth Amendment reasonableness inquiry and a search or seizure of a dwelling might be constitutionally defective if police officers entered without prior announcement, and remanded the case to determine whether the unannounced entry was reasonable under the circumstances.

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