WILSON V. ARKANSAS

This is an audio case brief of Wilson v. Arkansas, 514 U.S. 927 (1995). The audio brief provides a full case analysis. However a written summary of the case is provided below.

Table of Contents

FACTS

During November and December 1992, Sharlene Wilson made a series of narcotics sales to an informant acting at the direction of the Arkansas State Police. In late November, the informant purchased marijuana and methamphetamine at the home that Wilson shared with Bryson Jacobs.

On December 30, the informant telephoned Wilson at her home and arranged to meet her at a local store to buy some marijuana. According to testimony presented, Wilson produced a semiautomatic pistol at this meeting and waved it in the informant’s face, threatening to kill her if she turned out to be working for the police. Wilson then sold the informant a bag of marijuana.

The next day, police officers applied for and obtained warrants to search Wilson’s home and to arrest both her and Jacobs. Affidavits filed in support of the warrants set forth the details of the narcotics transactions and stated that Jacobs had previously been convicted of arson and firebombing. The search was conducted later that afternoon. Police officers found the main door to Wilson’s home open. While opening an unlocked screen door and entering the residence, they identified themselves as police officers and stated that they had a warrant.

Once inside the home, the officers seized marijuana, methamphetamine, valium, narcotics paraphernalia, a gun, and ammunition. They also found Wilson in the bathroom, flushing marijuana down the toilet. Wilson and Jacobs were arrested and charged with delivery of marijuana, delivery of methamphetamine, possession of drug paraphernalia, and possession of marijuana.

Before trial, Wilson filed a motion to suppress the evidence seized during the search. She asserted that the search was invalid on various grounds, including that the officers had failed to “knock and announce” before entering her home. The trial court summarily denied the suppression motion. After a jury trial, Wilson was convicted of all charges and sentenced to 32 years in prison.

The Arkansas Supreme Court affirmed Wilson’s conviction on appeal. The court noted that “the officers entered the home while they were identifying themselves,” but it rejected Wilson’s argument that “the Fourth Amendment requires officers to knock and announce prior to entering the residence.

Wilson Appealed to the U.S. Supreme Court.

ISSUES

Whether the common-law knock and announce principle forms a part of the Fourth Amendment reasonableness inquiry.

RULE

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.

APPLICATION / ANALYSIS

Firstly the court found that the common law principle of knock and and announce is a part of the fourth amendment reasonable inquiry.

Here is how the court explained its position.

The Fourth Amendment to 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, we have 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, our effort to give content to 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.

Our own cases have acknowledged that the common law principle of announcement is embedded in Anglo-American law, but we have never squarely held that this principle is an element of the reasonableness inquiry under the Fourth Amendment. We now so hold.

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 reasonableness of a search or seizure. Contrary to the decision below, we hold that in some circumstances an officer’s unannounced entry into a home might be unreasonable under the Fourth Amendment.

The court further added that although the knock and announce principle is part of the fourth amendment reasonableness inquiry, there are certain circumstances where an unannounced entry will be required.

Here is how the court explained its position:

This is not to say, of course, that every entry must be preceded by an announcement. The Fourth Amendment’s flexible requirement of reasonableness should not be read to mandate a rigid rule of announcement that ignores countervailing law enforcement interests. As even the defendant concedes, the common-law principle of announcement was never stated as an inflexible rule requiring announcement under all circumstances.

It has been recognized from the early common law that breaking is permissible in executing an arrest under certain circumstances.

We need not attempt a comprehensive catalog of the relevant countervailing factors here. For now, we leave to the lower courts the task of determining the circumstances under which an unannounced entry is reasonable under the Fourth Amendment. We simply hold that although a search or seizure of a dwelling might be constitutionally defective if police officers enter without prior announcement, law enforcement interests may also establish the reasonableness of an unannounced entry.

CONCLUSION

The judgement of the Arkansa supreme court was reversed and the case was remanded to the lower courts for further proceedings consistent with the courts ruling.

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