Mennella v. Office of Court Administration

How later courts describe this case

• declining to create bright-line rule regarding amount of time officers must wait after knocking and announcing
• holding fifteen to thirty seconds sufficient
• “The Fourth Amendment’s ‘knock and announce’ principle, given its fact-sensitive nature, cannot be distilled into a constitutional stop-watch where a fraction of a second assumes controlling significance.”
• trial court properly denied motion to suppress even though some of the events included in the affidavit occurred four years ago and officer did not apply for warrant until ten days after discovery of drug trafficking paraphernalia in trash of residence