Summary
The Indiana Supreme Court affirmed Mario Watkins’s convictions and the denial of his motion to suppress. The court held that Evansville police’s SWAT-style execution of the search warrant, including use of a battering ram and flash-bang grenade, was reasonable under Article 1, Section 11 of the Indiana Constitution under the Litchfield totality-of-the-circumstances test. The court also held that the search-warrant affidavit provided a substantial basis for probable cause under the Fourth Amendment.
Topics
Practice areas
Questions Presented
- Whether the execution of a search warrant using a battering ram, flash-bang grenade, and SWAT team violated Article 1, Section 11 of the Indiana Constitution.
- Whether the search warrant affidavit provided sufficient probable cause under the Fourth Amendment to believe contraband or evidence of a crime would be found at Watkins's home.
Holdings
- The Litchfield totality-of-the-circumstances test applies to the reasonableness of search warrant executions under Article 1, Section 11.
- The search warrant execution was not unreasonable under the totality of the circumstances.
- The search warrant affidavit provided a substantial basis for finding probable cause.
Key quotations
“The Litchfield test remains well-suited to assess the reasonableness of search warrant executions, making any new test unnecessary.” (at 344)
“The significant intrusion here did not outweigh the even more significant police interests.” (at 349)
Factual background
Evansville police obtained a search warrant based on a confidential informant's tip that cocaine, marijuana, and a gun were in Mario Watkins's home. They executed the warrant with a SWAT team using a battering ram, flash-bang grenade, and armored vehicle. The flash-bang grenade was deployed six inches inside the front door, where a nine-month-old infant was in a playpen. Officers found cocaine, marijuana, pills, cash, and a handgun inside. Watkins was arrested and charged with multiple felonies.
Procedural history
Watkins was convicted on multiple felony and misdemeanor charges after a jury trial. He appealed, challenging the search warrant execution under the Indiana Constitution and the search warrant affidavit under the Fourth Amendment. The Court of Appeals reversed, finding the search unreasonable. The State petitioned for transfer, which the Indiana Supreme Court granted, vacating the Court of Appeals opinion.