Lacey v. State

Summary

The Supreme Court of Indiana held that Article 1, Section 11 of the Indiana Constitution does not require police to obtain prior judicial authorization for a no-knock execution of a search warrant when exigent circumstances justify the entry. The court held that reasonableness must be evaluated under the totality of the circumstances existing when the warrant is executed, while identifying advance judicial authorization as the better practice when the need for a no-knock entry is known beforehand. The court affirmed the trial court's denial of Lacey's motion to suppress.

Holdings

1. The search warrant was supported by probable cause.
2. Article 1, Section 11 of the Indiana Constitution does not require police to obtain prior judicial authorization for a no-knock execution of a warrant when exigent circumstances justify the entry, even if those circumstances were known when the warrant was obtained.

Questions Presented

1. Whether the search warrant was supported by probable cause.
2. Whether Article 1, Section 11 of the Indiana Constitution required police to obtain prior judicial authorization for a no-knock execution of a search warrant when the exigent circumstances supporting the entry were known when the warrant was sought.

Disposition

affirmed