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Name: United States v. Combs
Case #: 03-30456
Court: US Court of Appeals
District 9 Cir
Opinion Date: 01/11/2005

Police officers serving a warrant on appellant’s home announced their presence but did not physically knock on appellant’s door before using a battering ram to break the door and enter the house. Appellant moved to suppress the evidence based on a violation of the “knock-notice” requirement. The appellate court affirmed the denial of the motion. The “knock and announce” principle is part of the reasonableness inquiry under the Fourth Amendment, and a physical knock is only one factor to be considered. The totality of circumstances must be examined to determine whether a given search was reasonably executed. Here, officers were concerned for their safety, and it appeared that methamphetamine was cooking at the time of the officers’ arrival. Police officers announced their presence over a loudspeaker and demanded entry. Given the totality of circumstances, the warrant’s execution complied with the requirements of the Fourth Amendment.