State v. Ruem, 313 P.3d 1156

Pierce County deputies sought to arrest Chantha Ruem at 10318 East McKinley Ave, where a mobile home sat adjacent to a house on the property.
The arrest warrant named Chantha and did not establish probable cause that he resided or was present at the mobile home that evening.
Ruem initially consented to deputies entering the mobile home but immediately revoked that consent.
Deputies entered after Ruem’s withdrawal, smelled burnt marijuana, and searched the mobile home, discovering marijuana plants, equipment, cash, and a handgun.
A later search warrant was executed at the mobile home yielding substantial contraband; Ruem was charged with manufacturing marijuana with a firearm and related offenses.
The Supreme Court granted review to consider Ferrier warnings and the admissibility of evidence obtained during the entry, ultimately holding Ferrier warnings were not required for entry to execute an arrest warrant, but the entry and subsequent searches were invalid for lack of probable cause and due to withdrawal of consent, leading to reversal and vacatur of Ruem’s conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ferrier warnings are required before entry to execute an arrest warrant.	Ruem argues Ferrier warnings are per se necessary.	State argues Ferrier warnings are not required when seeking entry to execute an arrest warrant.	Ferrier warnings are not required for entry to execute an arrest warrant.
Whether deputies had probable cause to believe Chantha resided at and was present in the mobile home.	Ruem contends there was insufficient probable cause to show presence.	State asserts residence/presence were supported by Chantha’s address and automobile on the property.	The arrest warrant did not authorize entry due to lack of probable cause to believe Chantha was present.
Whether Ruem's consent to enter was voluntary given the circumstances.	Ruem maintained consent was involuntary due to coercive entry and lack of Ferrier warning.	State contends consent was voluntary under totality of the circumstances.	Ruem's consent was not voluntary as entered, given withdrawal and coercive context.
Whether the independent source rule can save the later search warrant.	Evidence could be saved if independent of the unlawful entry.	Independent source must be genuinely independent of the illegal entry.	Independent source doctrine does not validate the later search warrant.

State v. Ferrier, 136 Wn.2d 103 (Wash. 1998) (warning required in Ferrier context; knock-and-talk)
State v. Khounvichai, 149 Wn.2d 557 (Wash. 2003) (Ferrier warnings limited to certain searches; not universal)
State v. Vy Thang, 145 Wn.2d 630 (Wash. 2002) (Ferrier warnings not always required for arrest warrants)
State v. Williams, 142 Wn.2d 17 (Wash. 2000) (consent issues in non-Ferrier contexts)
State v. Hatchie, 161 Wn.2d 390 (Wash. 2007) (plain view and presence considerations in home entries)
Payton v. New York, 445 U.S. 573 (1980) (arrest warrant entry principles into dwellings)
State v. Schoemaker, 85 Wn.2d 207 (Wash. 1975) (totality of the circumstances in determining voluntariness of consent)
Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (multifactor test for voluntary consent to search)
United States v. McWeeney, 454 F.3d 1030 (9th Cir. 2006) (consent may be withdrawn; remaining standards apply)
Afana, 169 Wn.2d 169 (Wash. 2010) (state exclusionary rule and privacy protections)