State v. Cash, 316 Ga. App. 324

No-knock search warrant issued Jan. 5, 2010 for residence, vehicles, curtilage in Peachtree City.
Affidavit based on anonymous tips from Jul. 2009 and surveillance with negative results.
Trash pull on Jan. 4, 2010 revealed marijuana; affiant cites drug-offense routines and potential firearms.
Affidavit asserts suspect possibly military and knowledgeable about firearms; requests no-knock for safety and to prevent evidence destruction.
Warrant executed without knocking; small amount of marijuana found belonging to Cash; no firearms disclosed on return.
Trial court granted suppression; appellate court reviews de novo and affirms suppression per no-knock validity analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether no-knock provision was adequately supported	Cash	State	No; invalid on basis of generalized assertions.
Whether affidavit presented particular facts justifying no-knock	Cash	State	No; lacks case-specific facts; fails Barnett-type standard.
Whether invalid no-knock provision taints execution of warrant	Cash	State	Yes; invalid provision renders execution illegal.
Whether suppression was proper given the above	Cash	State	Yes; evidence must be suppressed.

Poole v. State, 266 Ga. App. 113 (Ga. App. 2004) (de novo review when facts undisputed; no-knock context mirrors Barnett analysis)
Barnett v. State, 314 Ga. App. 17 (Ga. App. 2012) (blanket generalizations insufficient to justify no-knock; specific facts required)
Richards v. Wisconsin, 520 U.S. 385 (U.S. 1997) (no blanket exception for felony drug investigations to knock-and-announce)
Felix v. State, 241 Ga.App. 323 (Ga. App. 1999) (informant-based no-knock not present; officers knocked and announced)
Clark v. State, 245 Ga. App. 267 (Ga. App. 2000) (distinction between possession for personal use and distribution; no sales evidence)
Hunter v. State, 198 Ga. App. 41 (Ga. App. 1990) (no-knock warranted where weapons were indicated)