## Facts

- Police obtained a warrant to search Steiney Richards’ motel room for drugs and related items; the judge removed requested “no-knock” language from the warrant.
- Around 3:40 a.m., an officer knocked and falsely identified himself as maintenance; Richards opened the door slightly while it was secured by a chain.
- Richards saw a uniformed officer and quickly shut the door.
- Officers immediately forced entry, detained Richards as he attempted to flee, and found cash and cocaine in the bathroom.
- Richards moved to suppress, arguing the forced entry violated the Fourth Amendment’s knock-and-announce requirement.
- The trial court denied suppression, reasoning Richards’ conduct indicated a risk of escape or destruction of easily disposable evidence.
- The state supreme court affirmed based on a per se rule that knock-and-announce is never required when executing a warrant in felony drug investigations.

## Issues

1. Whether the Fourth Amendment allows a blanket exception to knock-and-announce for all felony drug investigations.
2. Whether the officers’ unannounced forced entry here was reasonable under the Fourth Amendment.

## Decision

- The Court rejected a categorical felony-drug-investigation exception to knock-and-announce.
- The Court held that no-knock entries must be justified case by case under the Fourth Amendment’s reasonableness standard.
- Applying that standard, the Court upheld the entry because the officers had reasonable suspicion, based on Richards’ door-closing reaction and the nature of the evidence sought, that announcing would allow destruction of evidence or facilitate flight.
- The Court affirmed the judgment upholding Richards’ conviction, while disapproving the state court’s per se rationale.

## Legal Principles

- The knock-and-announce requirement is part of the Fourth Amendment reasonableness inquiry, but it is not a rigid, exceptionless command.
- The Fourth Amendment does not permit a blanket rule excusing knock-and-announce in all felony drug investigations.
- Police may dispense with knock-and-announce only if they have reasonable suspicion, under the particular circumstances, that announcing would be dangerous, futile, or would hinder effective investigation (including by allowing destruction of evidence).
- The “reasonable suspicion” threshold is comparatively low, but it must be supported by case-specific facts and remain subject to judicial review.

## Conclusion

The Court held that offense-based categorical “no-knock” rules violate the Fourth Amendment, but it affirmed the search because the officers had case-specific reasonable suspicion that knocking and announcing would likely lead to destruction of narcotics evidence or facilitate escape.


Richards v. Wisconsin, 520 U.S. 385 (1997)