State of Washington v. Viengmone Khounvichai, 149 Wash. 2d 557

69 P.3d 862 (2003) · Supreme Court of Washington · June 5, 2003 · No. No. 72412-1

Summary

The Washington Supreme Court held that Ferrier warnings are not required when police seek consensual entry into a home solely to question a resident during a criminal investigation. The warnings are required when officers seek entry to obtain consent for a warrantless search for contraband or evidence. The court affirmed the Court of Appeals and upheld the admission of cocaine discovered during the encounter.

Holdings

  1. Ferrier warnings are required only when police seek entry into a home for the purpose of obtaining consent to conduct a warrantless search for contraband or evidence of a crime. They are not required when officers seek consensual entry merely to question or obtain information from an occupant.

Questions Presented

  1. Whether Washington's Ferrier warnings are required when police seek consensual entry into a home to question a resident during a criminal investigation rather than to obtain consent for a warrantless search.
  2. Whether the absence of Ferrier warnings invalidated Orr's consent to the officers' entry.

Disposition

affirmed

Cases Cited (17)

  • State v. Ferrier, 136 Wash. 2d 103, 960 P.2d 927 (1998)(followed)
  • State v. Hendrickson, 129 Wash. 2d 61, 917 P.2d 563 (1996)(followed)
  • State v. Williams, 142 Wash. 2d 17, 11 P.3d 714 (2000)(followed)
  • State v. Bustamante-Davila, 138 Wash. 2d 964, 983 P.2d 590 (1999)(followed)
  • State v. Kennedy, 107 Wash. App. 972, 29 P.3d 746 (2001)(criticized)
  • State v. Miller, 121 Wash. 153, 209 P. 9 (1922)(followed)
  • State v. O'Neill, 148 Wash. 2d 564, 62 P.3d 489 (2003)(followed)
  • State v. Hudson, 124 Wash. 2d 107, 874 P.2d 160 (1994)(followed)
  • Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966)(followed)
  • State v. Ladson, 138 Wash. 2d 343, 979 P.2d 833 (1999)(discussed)

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