Hudson v. Michigan

Supreme Court of the United States · 2006 · Criminal Procedure

547 U.S. 586 (2006)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentExclusionary RuleKnock-and-Announcesuppressionattenuationcausationsearch warrant

Facts

Police obtained a warrant to search Booker Hudson's home for drugs and firearms. When officers arrived, they announced their presence but waited only a short time, perhaps three to five seconds, before opening the unlocked front door and entering. Inside, officers found large quantities of drugs, including cocaine rocks in Hudson's pocket, and a loaded gun in the chair where he was sitting. Michigan conceded that the entry violated the knock-and-announce rule, so the dispute before the Court concerned only the remedy.

Issue

Does a violation of the Fourth Amendment knock-and-announce requirement require suppression of the evidence discovered during the execution of a valid search warrant? More specifically, should the exclusionary rule apply when police enter too quickly after announcing their presence but would have discovered the evidence during the warranted search anyway?

Rule

Suppression is not an automatic consequence of a Fourth Amendment violation. Evidence obtained after a knock-and-announce violation need not be excluded because the interests protected by the knock-and-announce rule do not include preventing the government from seeing or seizing evidence described in a valid warrant, and the deterrence benefits of exclusion in this context do not outweigh its substantial social costs.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Officers in Cleveland obtained a valid warrant to search Dana Ruiz's townhouse for methamphetamine and handguns. They knocked, yelled "police," and entered after waiting only two seconds, without any applicable exception; inside they found both items listed in the warrant.

Dana moves to suppress the methamphetamine and handguns solely because the officers entered too quickly. How should the court rule?

Explanation. The majority held that suppression is not the automatic remedy for a Fourth Amendment violation. When officers have a valid warrant, a knock-and-announce violation concerns the manner of entry, not the authority to search. The interests protected by knock-and-announce—life, property, privacy, and dignity—do not include preventing the government from seeing or seizing the evidence described in the warrant, so exclusion is inappropriate.