Hudson v. Michigan

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Following is the case brief for Hudson v. Michigan, United States Supreme Court, (2006)

Case summary for Hudson v. Michigan:

  • Police arrived at Hudson’s home after obtaining a warrant. Three to five seconds after announcing their presence, police entered Hudson’s home and found drugs and a firearm.
  • At trial, Hudson moved to have the evidence suppressed, claiming that the violation of the knock and announce rule violated his Fourth Amendment rights.
  • The trial court granted Hudson’s motion.
  • The Court held the subsequently discovered evidence is admissible since the social cost of excluding it is greater than the deterrent effect the knock and announce rule could have on police in preventing future rule violations. Introducing the discovered evidence does not violate the defendant’s Fourth Amendment rights.

Hudson v. Michigan Case Brief

Statement of the facts:

After obtaining a warrant, the police arrived at Hudson’s home. The police announced their arrival and waited about three to five seconds before entering Hudson’s home. The search yielded weapons and drugs. At trial, Hudson moved to suppress the evidence claiming that the police violated his Fourth Amendment right against unreasonable searches and seizures because they did not wait for a sufficient amount of time before entering his home. The trial court granted Hudson’s motion to suppress.

Procedural History:

The state appealed the motion and the Michigan court of appeals reversed. The Supreme Court of the United States later granted certiorari.

Rule of Law or Legal Principle Applied:

The exclusionary rule will not apply to knock and announce rule violations.

Issue and Holding:

Whether a knock and announce rule violation results in the exclusion of evidence founds in the subsequent search? No.

Judgment:

The Supreme Court affirmed the judgment of the state appellate court.

Reasoning:

  • Even when the police violate the knock and announce rule, subsequently discovered evidence may still be admitted at trial.

The Court identified the purpose of the knock and announce rule as protecting lives and preventing injury to both persons and their property.

Once a warrant is issued, an individual’s expectation of privacy in the evidence outlined in the warrant no longer exists. As a result, exclusion is not proper if the police fail to knock and announce their presence pursuant to procedure. This is because the individual’s violated interest has nothing to do with either the search or seizure of the evidence.

The Court emphasized that the exclusionary rule applies where the rule’s ability to discourage police misconduct outweighs the danger to society in letting criminals go. Preventing the exclusion of evidence discovered in violation of a safety rule provides little deterrence to police. However, doing such could have a detrimental impact on society. If the police wait too long, the officers may be harmed. In addition, police incentive to violate the rule is slight since the purpose is designed for the safety of all and a violation could result in a professional reprimand or civil suit.

Concurring or Dissenting opinions:

Concurring (Kennedy):

 The Court’s decision “should not be interpreted as suggesting that violations of the requirement (knock and announce) are trivial or beyond the law’s concern”.  Kennedy emphasized that the decision determined only that in the specific context of the knock and announce rule, a violation is not sufficiently related to the later discovery of evidence to result in a justification for suppression.

Dissenting (Breyer):

Violations of the knock and announce rule are frequent and there exists no evidence to support that the above mentioned deterrence is effective. The exclusionary rule should apply when the police violate the knock and announce rule. This is outlined in court precedent, which prohibits the admission of evidence obtained from an illegal search or seizure.

Significance:

Hudson v. Michigan established that police violations of the knock and announce rule do not warrant suppression of the evidence discovered subsequent to the violation. This is because the individual’s privacy interest has nothing to do with the safety purpose behind the rule.

Student Resources:

https://www.law.cornell.edu/supct/html/04-1360.ZS.html
https://www.radford.edu/content/va-chiefs/home/july-2006/hudson-v-michigan.html