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Name: People v. Murphy
Case #: S125572
Court: CA Supreme Court
District CalSup
Opinion Date: 12/28/2005

Murphy was on searchable probation. Sheriff’s officers decided to search her home based on evidence that she was selling drugs from the home. During surveillance of the home, officers approached a man right outside an open doorway of the home and yelled at him to lay down on the ground. Fearing persons in the house might arm themselves, destroy evidence, or flee, the officers entered the house without knocking. Once the officers were inside, Murphy admitted selling methamphetamine. Murphy challenged the search on knock-notice grounds. The appellate court agreed and reversed, and the prosecutor appealed. The Supreme Court reversed the ruling by the appellate court. The no-knock entry was justified by the exigent circumstances, including contemporaneous drug sales on the premises which raised the inference that more drugs were present inside, the officers’ knowledge of the search condition, and the unplanned noisy confrontation with the first suspect. Because the Court reversed on the knock-notice grounds, it did not consider the prosecutor’s alternative argument that the inevitable discovery doctrine applied and therefore validated the search despite a knock-notice violation.