Lane v. State, 513 S.W.3d 230

Adam Lane, a parolee, was staying at a Fort Smith hotel in January 2015 in violation of parole conditions (failed to report to parole officer and stayed away from approved residence).
Parole officer Adam Nading and a Fort Smith police officer went to the hotel; the manager used an electronic key to open the door for officers, who entered without knocking or announcing.
Lane was arrested in bed with a female companion; officers observed methamphetamine baggies and later found more methamphetamine and a handgun.
After arrest Lane executed a sworn statement admitting responsibility for the contraband; he was charged with several drug- and firearm-related offenses and tried as a habitual offender.
Lane moved to suppress the evidence, arguing the officers entered without a warrant and failed to knock-and-announce; he also moved in limine to exclude his affidavit.
The circuit court denied both motions; Lane was convicted and sentenced to 70 years. The Arkansas Supreme Court affirmed.

Issue	Plaintiff's Argument (Lane)	Defendant's Argument (State)	Held
1. Lawfulness of warrantless entry	Entry violated Fourth Amendment; no warrant	Lane had signed parole conditions consenting to warrantless searches; officers had reasonable grounds to investigate parole violation	Entry lawful under parole consent and reasonable grounds; search valid
2. Applicability of knock-and-announce to parolees	Knock-and-announce required; officers violated it by entering unannounced	Parole status (consent/ diminished privacy) permits unannounced entry	Knock-and-announce applies to parolees; officers violated that requirement
3. Remedy for knock-and-announce violation (exclusionary rule)	Suppression warranted because constitutional rule breached	Exclusion not appropriate; Hudson establishes exclusion not required for knock-and-announce violations	Exclusionary rule does not apply to knock-and-announce violations as to parolees; evidence admissible
4. Admissibility of Lane’s sworn statement	Statement should be excluded under Ark. R. Evid. 410, 403, 801	Statement was not an offer to plead guilty and objection on other grounds not preserved	Statement admissible; Rule 410 inapplicable; other objections not preserved

Wilson v. Arkansas, 514 U.S. 927 (incorporation of the common-law knock-and-announce rule into Fourth Amendment reasonableness analysis)
Hudson v. Michigan, 547 U.S. 586 (exclusionary rule does not apply to knock-and-announce violations)
Cherry v. State, 302 Ark. 462 (parolees’ diminished expectation of privacy; consent-in-advance to searches upheld)
Richards v. Wisconsin, 520 U.S. 385 (rejection of blanket exceptions to knock-and-announce)
Samson v. California, 547 U.S. 843 (upholding suspicionless searches of parolees under parole terms)
Mazepink v. State, 336 Ark. 171 (prior Arkansas case applying exclusion for knock-and-announce; overruled by Hudson on this point)
Green v. Butler, 420 F.3d 689 (rejecting blanket exception to knock-and-announce for parole/probation searches)
Hudson v. Palmer, 468 U.S. 517 (prisoners’ diminished expectation of privacy)