State v. Wallin
The Second DCA addressed an issue of first impression for the district: whether Florida's knock-and-announce statute for arrest warrants, section 901.19, applies when officers encounter a completely open door. The court held the statute, by its plain language, applies only to forcible entries, and because officers peaceably entered through Wallin's wide-open motel room doors to execute a valid arrest warrant, no knock-and-announce violation occurred, reversing suppression of the drug evidence found inside.
Key facts
- Officers executed a valid arrest warrant for Wallin at a motel room with completely open doors and entered peaceably without using force to search for and seize drug evidence.
- Wallin moved to suppress the drug evidence, arguing the officers violated Florida's knock-and-announce statute for arrest warrants (section 901.19) by failing to knock before entering.
- +2 more key facts with a free trial
Why it matters
This decision clarifies, for the first time in the Second DCA, that the knock-and-announce requirement for arrest warrants under section 901.19 does not apply when officers encounter an open door and make a non-forcible… — full analysis with a trial
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