Hudson v. Michigan Case Brief

Facts of the case

Booker T. Hudson was convicted of drug and firearm possession in state court after police found cocaine and a gun in his home. The police had a search warrant, but failed to follow the Fourth Amendment knock and announcerule which requires police officers to wait 20-30 seconds after knocking and announcing their presence before they enter the home. The trial judge ruled that the evidence found in the home could therefore not be used, but the Michigan Court of Appeals reversed based on two Michigan Supreme Court cases that created an exception to the suppression of evidence when the evidence in question would have inevitably been found.

CONCLUSION

The Court determined that the exclusionary rule was inapplicable and suppression of the evidence was not warranted because violation of the knock-and-announcerule did not require the suppression of all evidence found in the search. Moreover, the Court held that the constitutional violation of an illegal manner of entry was not a but-for cause of obtaining the evidence. The Court also noted that the interests that were violated, preventing the Government from seeing or taking evidence described in a warrant, had nothing to do with the seizure of the evidence. In conclusion, the Court ruled that the social costs of applying the exclusionary rule to knock-and-announce violations were considerable, the incentive for such violations was minimal to begin with, and the extant deterrence against them were substantial. As such, the Court affirmed the judgment of the state appellate court.

  • Advocates: Timothy A. Baughman argued the cause for Respondent David A. Moran argued the cause for Petitioner David B. Salmons argued the cause for Respondent
  • Petitioner: Booker T. Hudson, Jr.
  • Respondent: Michigan
  • DECIDED BY:Roberts Court
  • Location: –
Citation: 547 US 586 (2006)
Granted: Jun 27, 2005
ReArgued: May 18, 2006
Decided: Jun 15, 2006
Hudson v. Michigan Case Brief