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Kentucky v. King | 563 U.S. 452 (2011)
In emergency situations, the doctrine of exigent circumstances provides a well-established exception to the Fourth Amendment’s search warrant requirement. Usually, exigent circumstances are a suspect’s own doing; for example, when a suspect attempts to destroy incriminating evidence before police officers can seize it. But in Kentucky versus King, the United States Supreme Court addressed the implications of police officers who contribute to exigent circumstances with their own conduct.
Police officers in Lexington, Kentucky, chased a suspected drug dealer into an apartment complex. The officers didn’t know which apartment he had entered but suspected it was one of two apartments located in a specific part of the complex. The officers smelled marijuana smoke coming from inside one of the two apartments. They knocked on the apartment’s door and loudly announced their identity as police officers. No one came to the door, but the officers heard noises coming from within the apartment that sounded like the occupants were moving things around inside. Because the officers believed the occupants were going to destroy drugs, the officers, without a warrant, kicked the door in and entered the apartment. Inside they found Hollis King and two other people in possession of multiple types of illegal drugs and cash. King was arrested and later indicted by a state grand jury for drug-trafficking.
In a pretrial motion, King contended that the trial court should suppress the evidence of drug trafficking because the officers’ warrantless entry into the apartment violated the Fourth Amendment. The prosecution responded that the officers’ belief that the occupants were going to destroy the drugs constituted exigent circumstances. The trial court agreed with the prosecution and denied King’s motion. King entered a conditional guilty plea, preserving his right to appeal the Fourth Amendment issue. The Kentucky Court of Appeals affirmed the trial court’s ruling.
The Kentucky Supreme Court, however, held that the trial court erred by denying King’s motion to suppress. The state high court concluded that the officers had themselves created the exigent circumstances by forcefully knocking on the apartment door and loudly announcing their identity as police officers, thus leading the occupants to attempt to destroy the drugs. The United States Supreme Court granted cert.
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