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III. Richards v. Wisconsin: Whether or Not to Knock and Announce
The United States Supreme Court, in Richards v. Wisconsin,62 recently held that the "Fourth Amendment does not permit a blanket exception to the knock-and-announce requirement for felony drug investigations."63 In Richards, police officers obtained a warrant that did not have the advance authorization of the magistrate for a no-knock entry to search the defendant's hotel room for drugs; the search warrant was based on an investigation that had established substantial evidence as to the drug sales that the defendant was conducting out of his hotel room.64 When the officers knocked on the door of the hotel room, one officer stated that he was a maintenance man, and he was correspondingly dressed.65 Other officers were dressed in plain clothes, and at least one officer was in a police uniform.66 When the defendant opened the door, he spotted the uniformed officer and quickly closed the door, at which time the officers "began kicking and ramming the door to gain entry to the locked room."67 Upon entry, the officers caught the defendant trying to escape. When the officers searched the premises they found cash and cocaine hidden in the bathroom.68
At trial, the...