Hudson v. Michigan

Hudson v. Michigan Case Brief

United States Supreme Court
547 U.S. 586 (2006)

ISSUE: Does a violation of the Wilson knock-and-announce rule when police were conducting a legal, warranted search of D's house subject the evidence found pursuant to the search to the Exclusionary Rule?
HOLDING: No, an impermissible manner of entry does not necessarily trigger the Exclusionary Rule.
FACTS:
  • Police obtained a warrant to search D's house for drugs and firearms and did indeed find large quantities of drugs and a loaded gun
  • When police arrived, they knocked, announced their presence, but only waited 3-5 seconds before turning the knob and entering
PROCEDURAL HISTORY:
  • D moved to suppress the fruits of the search as violative of her 4th Amdt. rights
  • Trial Ct. granted motion
  • Ct. App. reversed & Sup. Ct. denied leave to appeal
REASONING:
  • Not but-for cause: The constitutional violation of an illegal manner of entry was not the but-for cause of obtaining the evidence, as the police would still have obtained the evidence but-for the illegal manner of entry
    • Never held that evidence is the fruit of the poisonous tree when it would have come to light but-for the illegal actions of the police
  • Exclusionary Rule inapplicable: Since the interests thatwere violated have nothing to do with the seizure of the evidence, the Exclusionary Rule is inapplicable
    • 4th Amdt. entitles citizens to shield their persons, houses, papers, and effects from govt. intrusion until a valid warrant is issued
    • But K&A rule only assures the opportunity to collect oneself before answering the door and prepare for the police entry
  • Social costs too high: Imposing the massive remedy of the Exclusionary Rule for K&A violations would generate a constant flood of alleged failures to observe the rule and claims that there was no justification for a no-knock entry
    • Difficult to determine on each appeal what constituted a "reasonable time" for entry and even how long the police did in fact wait
    • Officers might end up waiting longer than necessary, which could result in destruction of evidence or increased violence against the officers
    • Deterrence couldn't seek to achieve a whole lot where the K&A rule can already be overcome by reasonable suspicion (Richards)
  • Deterrence not necessary now: Cannot assume that exclusion in this context is necessary deterrence simply because it was necessary deterrence in different contexts long ago
    • 1983 has made civil rights actions more available to aggrieved persons
    • Civil liability is an effective deterrent
    • Increasing professionalism in police forces and a new emphasis on internal police discipline
COMMENTS:
  • Rule: The exclusionary rule does not apply when law enforcement officers violate the so-called "knock and announce" rule of Wilson v. Arkansas.

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