Richards v. Wisconsin
Supreme Court
520 U.S. 385 (1997)
Police obtained a warrant to search Richards's (defendant) hotel room for drugs; one officer disguised himself as a maintenance man, but once Richards cracked the door open and recognized them as police, they kicked the door in and found cash, cocaine, and Richards attempting to flee. Richards moved to suppress the evidence for failure to knock and announce; the trial court denied the motion, and the state supreme court affirmed on the theory that felony drug investigations, given their inherent dangers and risk of evidence destruction, categorically never require police to knock and announce.
Whether it is permissible to adopt a per se rule that police need never knock and announce their presence when executing a search warrant in a felony drug investigation, on the theory that exigent circumstances are frequently present in such cases.