Youngbey v. March, 676 F.3d 1114

Appellees allege Fourth Amendment violations and related state-law claims from no-knock, nighttime entry at 1312 Queen Street, NE.
Detective March obtained a search warrant based on the Mallory murder investigation identifying John Youngbey as the principal suspect.
The warrant sought firearms and related items at 1312 Queen Street, and the form allowed daytime/any time of day or night.
Officers conducted a 4:00 a.m. entry without knocking or announcing.
Officers and supervisors had substantial information before entry, including the killer’s confession and probable cause finding, indicating a firearm would be found at the residence.
District Court denied qualified immunity; panel reversed, holding the no-knock and nighttime entry did not violate clearly established law and remanded for trial on remaining issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether no-knock entry complies with Fourth Amendment in this case	Youngbey asserts no-knock violated clearly established law	March/defendants argue factual particularization supports no-knock	Not clearly established; qualified immunity applies
Whether nighttime execution was valid under the warrant	Youngbey argues nighttime execution violated the warrant’s scope	Warrant authorized daytime or nighttime; no clear invalidation	Not clearly established; qualified immunity applies
Whether the district court’s denial of qualified immunity should be reversed	Appellees contend immunity does not apply due to unreasonable entry	Officers had particularized information supporting reasonable belief	Yes; reverse for the two issues, remand on remaining claims

Richards v. Wisconsin, 520 U.S. 385 (1997) (no-knock exceptions require case-specific analysis; blanket rules prohibited)
Hudson v. Michigan, 547 U.S. 586 (2006) (knock-and-announce principles apply to reasonableness of entry)
Behrens v. Pelletier, 516 U.S. 299 (1996) (objective reasonableness governs qualified immunity)
Wilson v. Layne, 526 U.S. 603 (1999) (objective legal reasonableness standard; not subjective intent)
Pearson v. Callahan, 555 U.S. 223 (2009) (clearly established law analysis governs qualified immunity)
Crippen, 371 F.3d 842 (2004) (no bright-line rules; evaluate facts for exigent circumstances)
Ramirez, 523 U.S. 65 (1998) (no-knock justified by specific danger circumstances)
Geraldo, 271 F.3d 1112 (2001) (firearm presence + specific threat can excuse knock-and-announce)
Kornegay v. Cottingham, 120 F.3d 392 (1997) (distinguishable facts; generalized danger not enough)
Estate of Phillips v. District of Columbia, 455 F.3d 397 (2006) (analysis of prevailing law on qualified immunity)