Background - Evansville police obtained a search warrant after a long‑time confidential informant reported seeing Mario Watkins at his home with a gun, >10 grams of crack cocaine, and marijuana; surveillance corroborated short‑term traffic and suspected drug activity. - Police planned a SWAT entry considering the house layout, Watkins’s violent criminal history, and the reported presence of multiple adults, drugs, and a firearm. - Twelve SWAT officers arrived in an armored vehicle; officers breached the front door with a battering ram, announced presence, and deployed a flash‑bang six inches inside the doorway after a brief "quick peek." A nine‑month‑old infant was in a playpen in the room where the flash‑bang detonated. - Officers arrested Watkins and recovered crack cocaine, marijuana (706 g), pills, scales, cash, and a .40 caliber handgun; Watkins claimed everything in the house was his. - Watkins moved to suppress, arguing the warrant lacked Fourth Amendment probable cause and that the execution violated Article 1, Section 11 of the Indiana Constitution; the trial court denied suppression, a jury convicted on several drug and nuisance counts, and a split Court of Appeals panel reversed on the state constitutional claim. The Indiana Supreme Court granted transfer. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---| | Whether Litchfield totality‑of‑the‑circumstances test governs reasonableness of search‑warrant executions under Article 1, §11 | State urged deference and proposed a "no reasonable officer" test for warrant executions | Watkins argued Litchfield test should apply to execution reasonableness | Court held Litchfield governs; rejected the "no reasonable officer" test | | Whether the SWAT entry (battering ram, flash‑bang, armored vehicle, many officers) was unreasonable under Article 1, §11 | Watkins: intrusion was excessive (military‑style assault), flash‑bang into room with infant unreasonable | State: tactics justified by dangerousness, gun, drugs, Watkins’s history, and corroboration | Under Litchfield balance, the intrusion was high but justified by substantial law‑enforcement needs; entry was reasonable | | Whether the affidavit provided probable cause under the Fourth Amendment to search the house | Watkins: affidavit insufficient to tie contraband to the residence (relied on transient observations) | State: CI was reliable and observed >10g of crack at the specific address; surveillance corroborated | Court found a substantial basis for probable cause; upheld the warrant | | Admissibility of tactics like flash‑bangs generally (scope of review) | Watkins relied on Seventh Circuit flash‑bang precedent to show unreasonableness | State emphasized Indiana totality approach and officer precautions (quick peek, placement) | Court cautioned flash‑bangs should be exceptional but concluded use here, given precautions and danger, did not violate Article 1, §11 | ### Key Cases Cited Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (establishes totality‑of‑the‑circumstances test for reasonableness under Article 1, §11) Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause review requires a practical, commonsense determination; substantial‑basis standard) Lacey v. State, 946 N.E.2d 548 (Ind. 2011) (applies Litchfield to residential entries and discusses no‑knock authority) Zanders v. State, 73 N.E.3d 178 (Ind. 2017) (reasonableness claims under Article 1, §11 reviewed de novo and Litchfield affirmed as guiding) Membres v. State, 889 N.E.2d 265 (Ind. 2008) (probable cause requires link between contraband and place to be searched) Walker v. State, 829 N.E.2d 591 (Ind. Ct. App. 2005) (affidavit invalid where it tied drugs to a transient person but not to the premises) Merritt v. State, 803 N.E.2d 257 (Ind. Ct. App. 2004) (similar rule: need facts connecting contraband to place searched) Carpenter v. State, 18 N.E.3d 998 (Ind. 2014) (emphasizes heightened protection for the home under Article 1, §11)