Hudson v. Michigan
547 U.S. 586 (2006)
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Rule of Law:
The exclusionary rule does not require suppression of evidence seized in violation of the Fourth Amendment's 'knock-and-announce' requirement when police execute a valid search warrant.
Facts:
- Police in Detroit, Michigan, obtained a warrant to search the home of Booker Hudson for drugs and firearms.
- Upon arriving at Hudson's home, police announced their presence.
- After announcing, police waited only three to five seconds before turning the knob of the unlocked front door and entering.
- Inside, police discovered large quantities of cocaine, some of which was in Hudson's pocket.
- Police also found a loaded firearm lodged in the cushion of the chair where Hudson was sitting.
Procedural Posture:
- Booker Hudson filed a motion to suppress the evidence in the Michigan trial court, which granted the motion.
- On interlocutory review, the Michigan Court of Appeals, an intermediate appellate court, reversed the trial court's suppression order.
- The Michigan Supreme Court, the state's highest court, denied Hudson's application for leave to appeal.
- At trial, Hudson was convicted of drug possession.
- Hudson appealed his conviction to the Michigan Court of Appeals, arguing the evidence should have been suppressed, but the court affirmed the conviction.
- The Michigan Supreme Court again declined to hear the case.
- The U.S. Supreme Court granted certiorari to decide the issue.
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Issue:
Does the exclusionary rule require suppression of evidence seized in a search following a violation of the 'knock-and-announce' rule?
Opinions:
Majority - Justice Scalia
No. The exclusionary rule is not the appropriate remedy for a violation of the knock-and-announce rule. The Court's reasoning is based on three main points. First, the interests protected by the knock-and-announce rule—namely, the protection of human life, property, and privacy and dignity from sudden intrusions—have no causal relationship to the seizure of evidence that police already had a warrant to find. Second, the social costs of applying the exclusionary rule in this context, such as the risk of letting dangerous criminals go free and generating extensive litigation over entry timing, are too high. Third, the deterrence benefits are low because alternative remedies, such as civil rights lawsuits under 42 U.S.C. § 1983 and increased police professionalism and internal discipline, adequately deter police from violating the rule.
Dissenting - Justice Breyer
Yes. The exclusionary rule should apply because it is the only effective deterrent against knock-and-announce violations. The majority's decision destroys the strongest legal incentive for police to comply with this constitutional requirement. The dissent argues that the majority misapplies causation principles, as the illegal entry was an inseparable part of the search that yielded the evidence. Furthermore, alternative remedies like civil suits have historically proven inadequate to deter police misconduct, which was the primary reason the Court applied the exclusionary rule to the states in Mapp v. Ohio. By creating this exception, the Court weakens a critical Fourth Amendment protection for the sanctity of the home.
Concurring - Justice Kennedy
No. While knock-and-announce violations are serious matters, the causal link between such a violation and the subsequent discovery of evidence pursuant to a lawful warrant is too attenuated to justify suppression. The failure to wait a few more seconds at the door cannot be said to have caused the discovery of the evidence. However, this decision should not be interpreted as trivializing the knock-and-announce requirement, and the continued operation of the exclusionary rule in other contexts is not in doubt. Justice Kennedy also noted that if a widespread pattern of violations were to emerge, the Court might need to reconsider the issue.
Analysis:
This decision significantly narrows the application of the exclusionary rule, creating a categorical exception for knock-and-announce violations. It reflects the Court's increasing use of a cost-benefit analysis to limit the rule's scope, emphasizing that suppression is a last resort. The ruling effectively shifts the remedy for these Fourth Amendment violations from the suppression of evidence in criminal court to civil liability, which many critics argue is a far less effective deterrent. The case signals a greater willingness by the Court to find the causal chain between a constitutional violation and the discovery of evidence too attenuated to justify exclusion, a principle that may be applied to other areas of search and seizure law.
