Supreme Court of the United States

United States v. Ramirez

March 4, 1998523 U.S. 65

Summary

Chief Justice Rehnquist, writing for a unanimous Court, held that property damage during a no-knock entry does not require a heightened showing of exigent circumstances beyond the reasonable-suspicion standard established in Richards v. Wisconsin. The manner of executing a warrant remains subject to Fourth Amendment reasonableness, but breaking a single garage window to prevent access to suspected weapons was reasonable here. The Court also held that 18 U.S.C. § 3109 incorporates common-law exceptions to the announcement requirement, including an exigent-circumstances exception governed by the Richards standard. It reversed the Court of Appeals and remanded. There were no separate opinions.

Holding

  • The standard governing a no-knock entry that involves property damage.. Property damage does not require a higher justification for a no-knock entry than reasonable suspicion that announcement would be dangerous, futile, or detrimental to the investigation.
  • The constitutionality of the entry and property damage in this case.. The officers' entry and breaking of a single garage window did not violate the Fourth Amendment.
  • Whether § 3109 permits an unannounced entry under exigent circumstances.. Section 3109 codifies common-law exceptions to the announcement requirement, including an exigent-circumstances exception measured by the Richards reasonable-suspicion standard; the officers satisfied that exception.

Docket 96-1469

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