Hudson v. Michigan
Citation: 547 U.S. 586 (2006)
Facts
Police violated the knock-and-announce rule before entering Hudson’s home. They found drugs and a firearm. Hudson moved to suppress all evidence on the ground that it was the fruit of the knock-and-announce violation.
Issue
Does a violation of the knock-and-announce requirement require suppression of all evidence discovered in the subsequent search?
Holding
No. Suppression is not the appropriate remedy for knock-and-announce violations. The exclusionary rule does not apply because the causal connection between the knock-and-announce violation and the discovery of evidence is too attenuated.
Rule
No suppression for knock-and-announce violations: The exclusionary rule requires a sufficient causal connection between the constitutional violation and the evidence obtained. A knock-and-announce violation does not cause the discovery of evidence; the police would have discovered the same evidence through the valid warrant search regardless. Other remedies (civil suits, departmental discipline) are available and adequate.
Significance
- Virtually eliminated suppression as a remedy for knock-and-announce violations, substantially reducing the practical importance of Wilson v. Arkansas and Richards v. Wisconsin
- The exclusionary rule’s “but for” causation analysis: if evidence would have been found anyway under the lawful warrant, the antecedent knock-and-announce violation does not taint it
- Justice Kennedy’s concurrence (providing the fifth vote) noted that the holding does not extend to other constitutional violations where causal connection is closer
- Illustrates the Court’s retreat from the exclusionary rule in cases with attenuated connection between violation and evidence