HEADNOTE: OFFICERS WHO FAILED TO REQUEST A SEARCH WARRANT AUTHORIZING NO-KNOCK ENTRY HAD NO PARTICULARIZED KNOWLEDGE TO JUSTIFY A NO-KNOCK ENTRY OTHER THAN WHAT WAS ALREADY KNOWN AT THE TIME THEY SECURED THE WARRANT. In Wynn v. State, 117 Md. App. 133 (1997), rev'd on other grounds, 351 Md. 307 (1998); Lee v. State, 139 Md. App. 79, cert. granted, 366 Md. 246 (2001); Davis v. State, 144 Md. App 144, cert. granted, ___ Md. ____ (2002); and State v. Riley, 147 Md. App. 113 (2002), we considered the environs of Maryland law with regard to no-knock entries. Not indifferent to the rough-and-ready world in which Fourth Amendment principles are tested, we artlessly assumed these cases might begin, ever so slightly, to close the doors with regard to no-knock entries. Unfortunately, this case again shows that the doors of Fourth Amendment issues, like wisdom, are never shut, even temporarily.
