The U.S. Supreme Court case Sharlene Wilson v. Arkansas in 1994 revolved around the issue of whether or not police officers are required to knock and announce their presence before executing a search warrant, even if they suspect that doing so could lead to the destruction of evidence. The court ruled unanimously that while there is no absolute rule requiring law enforcement officials to always knock and announce themselves, this principle forms part of the Fourth Amendment's reasonableness inquiry. In other words, it should be considered as one factor among many when determining if an entry was reasonable under specific circumstances. However, failure to do so does not necessarily invalidate a search or seizure; instead courts must consider all relevant factors on a case-by-case basis.

In the dissenting opinion for Sharlene Wilson v. Arkansas, Justice John Paul Stevens argued that the majority's decision to create a flexible rule regarding "knock and announce" police entries was too vague and could lead to potential abuses of power. He contended that there should be a clear standard requiring law enforcement officers to knock and announce their presence before entering a home unless they have specific reasons not to do so, such as immediate danger or risk of evidence destruction. By allowing exceptions based on 'reasonable suspicion', he feared it would become an easy excuse for officers not following protocol in most cases. Furthermore, he expressed concern about how this ruling might affect marginalized communities who are often disproportionately targeted by aggressive policing tactics.