Steiney Richards Case Brief Summary

History: Steiney Richards was tried and convicted of possession with intent to deliver a controlled substance. Richards appealed the trial court’s decision, the Court of Appeals affirmed. Richards then appealed to the Wisconsin Supreme Court and that court affirmed the appellate court’s ruling. (201 Wis. 2d 845, 549 N.W.2d 218 (1996)). Richards appealed to the U.S. Supreme Court, certiorari was granted.
Facts: After an investigation revealed substantial evidence that Steiney Richards was involved in dealing drugs from hotel rooms in Madison, Wisconsin, the police obtained a search warrant for Richards’ hotel room on December 31, 1991. Officer’s arrived at the hotel room at 3:40 A.M. with at least one uniformed officer and several other plain clothes officers. When Officer Pharo, dressed as a maintenance man knocked on the door and announced he was maintenance Richards opened the chained door. Upon seeing the uniformed officer standing behind Officer Pharo, Richards slammed the door and retreated into the hotel room. The
In Wilson v. Arkansas, 514 U.S. 927, 934, 133 L. Ed. 2d 976, 115 S. Ct. 1914 (1195), this court recognized that the “flexible requirement of reasonableness should not be read to mandate a rigid rule of announcement that ignores countervailing law enforcement interests.” The circumstances surrounding the execution of the warrant reveal that Richards was most likely in possession of drugs at the time the officers arrived, and that Richards’ act of slamming the door after seeing police would lead police to reasonably believe that he was likely to either destroy the drugs or attempt to escape. In lights of the circumstances as they were at the time officers arrived at the hotel room the police were justified in their decision not to knock and announce before entering the room in order to prevent the destruction of