Richards v. Wisconsin Case Brief Summary | Law Case Explained

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

When you arrive at a person’s front door, it’s only polite to knock. But if you’re a police officer with a search warrant and the door belongs to a drug dealer, the expectations can get a little trickier, as evidenced by the 1997 case of Richards versus Wisconsin.

In a previous case, Wilson versus Arkansas, the United States Supreme Court held that the Fourth Amendment incorporated the common-law knock and announce rule. That rule generally requires police officers executing a search warrant at a residence to knock on the front door, announce their identity and purpose, and wait a reasonable amount of time before forcibly entering the residence.

In Richards, Police officers developed probable cause that Steiney Richards was selling cocaine out of a hotel room. The officers applied for a search warrant for the room. In their warrant application, the officers asked the judge to designate the warrant as a no-knock warrant. Although the judge issued the warrant, the judge refused to designate it as a no-knock warrant.

The officers executed the warrant at 3:40 a.m. They knocked on the door of Richards’s room and pretended to be a maintenance man. Richards cracked open the door, with the chain still on the door, and saw a uniformed police officer outside. He then slammed the door shut. After waiting two or three seconds, the officers forced entry into the room, yelling, quote, “search warrant,” unquote, only as they entered the room. Once inside, they saw Richards trying to escape through a window. The officers arrested him and seized cocaine found in the room.

Richards was charged in state court with possession of cocaine with intent to distribute it. He moved to suppress the drugs on the ground that the officers violated the knock and announce rule. The trial court denied the motion on the ground that there were exigent circumstances supporting the officers’ forcible entry without complying with the rule. Richards entered a conditional no-contest plea and reserved his right to appeal the suppression issue.

On appeal, the Wisconsin Court of Appeals affirmed Richard’s conviction. Richards appealed to the Wisconsin Supreme Court.

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