United States v. Shaheem Johnson

Procedural Posture

The defendant, Shaheem Johnson, was convicted of being a felon in possession of a firearm. The district court sentenced him to 120 months imprisonment, enhanced by two levels under U.S. Sentencing Guideline § 2K2.1(a)(4)(A) because it determined that his prior conviction for Maryland assault with intent to commit a felony constituted a "crime of violence." Johnson appealed this sentencing enhancement.

Statutory References

Key Legal Definitions

Rule Statements

"To qualify as a crime of violence under the elements clause, the statutory offense must involve a substantial risk that physical force will be used in the commission of the offense."

"A prior conviction qualifies as a crime of violence if its elements are such that the offense is one that involves as an element a substantial risk that physical force against the person or property of another may be used in the course of its commission."

Q: What is United States v. Shaheem Johnson about?

United States v. Shaheem Johnson is a case decided by Fourth Circuit on July 8, 2025.

Q: What court decided United States v. Shaheem Johnson?

United States v. Shaheem Johnson was decided by the Fourth Circuit, which is part of the federal judiciary. This is a federal appellate court.

Q: When was United States v. Shaheem Johnson decided?

United States v. Shaheem Johnson was decided on July 8, 2025.

Q: What is the citation for United States v. Shaheem Johnson?

The citation for United States v. Shaheem Johnson is 143 F.4th 212. Use this citation to reference the case in legal documents and research.

Q: What is the full case name and citation for this Fourth Circuit decision?

The case is United States of America v. Shaheem Johnson, and it is a Fourth Circuit Court of Appeals decision, though a specific citation number is not provided in the summary.

Q: Who were the parties involved in the United States v. Shaheem Johnson case?

The parties were the United States of America, acting as the appellant, and Shaheem Johnson, the appellee who was appealing the district court's decision.

Q: What was the primary issue decided by the Fourth Circuit in United States v. Shaheem Johnson?

The primary issue was whether the "knock-and-announce" rule was violated by law enforcement officers during their entry into Shaheem Johnson's apartment, which would have required suppression of evidence.

Q: When did the Fourth Circuit issue its decision in this case?

The provided summary does not specify the exact date the Fourth Circuit issued its decision, only that it affirmed the district court's ruling.

Q: Where did the events leading to the search of Shaheem Johnson's apartment take place?

The events leading to the search occurred at Shaheem Johnson's apartment, and the Fourth Circuit's jurisdiction covers federal cases originating from that region.

Q: What was the nature of the dispute in United States v. Shaheem Johnson?

The dispute centered on whether evidence seized from Shaheem Johnson's apartment should be suppressed due to an alleged violation of the "knock-and-announce" rule during the execution of a search warrant.

Q: Is United States v. Shaheem Johnson published?

United States v. Shaheem Johnson is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in United States v. Shaheem Johnson?

The court ruled in favor of the defendant in United States v. Shaheem Johnson. Key holdings: The Fourth Circuit held that the "knock-and-announce" rule requires officers to announce their presence and purpose before executing a warrant, but does not mandate a specific waiting period before forced entry.; The court found that officers adequately announced their presence and purpose before entering Johnson's apartment, satisfying the rule's requirements.; The court determined that the brief delay in Johnson's response to the knock and announcement did not render the entry unreasonable under the Fourth Amendment.; The court held that suppression of evidence is an "extreme sanction" and is not automatically required for every technical violation of the "knock-and-announce" rule.; The court affirmed the district court's denial of the motion to suppress, concluding that the officers' actions were constitutional..

Q: Why is United States v. Shaheem Johnson important?

United States v. Shaheem Johnson has an impact score of 15/100, indicating narrow legal impact. This decision reinforces that the "knock-and-announce" rule is not a rigid mandate for a specific waiting period, but rather a flexible standard of reasonableness. It clarifies that minor delays in occupant response, without more, will not automatically trigger the exclusionary rule, providing guidance to law enforcement on warrant execution.

Q: What precedent does United States v. Shaheem Johnson set?

United States v. Shaheem Johnson established the following key holdings: (1) The Fourth Circuit held that the "knock-and-announce" rule requires officers to announce their presence and purpose before executing a warrant, but does not mandate a specific waiting period before forced entry. (2) The court found that officers adequately announced their presence and purpose before entering Johnson's apartment, satisfying the rule's requirements. (3) The court determined that the brief delay in Johnson's response to the knock and announcement did not render the entry unreasonable under the Fourth Amendment. (4) The court held that suppression of evidence is an "extreme sanction" and is not automatically required for every technical violation of the "knock-and-announce" rule. (5) The court affirmed the district court's denial of the motion to suppress, concluding that the officers' actions were constitutional.

Q: What are the key holdings in United States v. Shaheem Johnson?

1. The Fourth Circuit held that the "knock-and-announce" rule requires officers to announce their presence and purpose before executing a warrant, but does not mandate a specific waiting period before forced entry. 2. The court found that officers adequately announced their presence and purpose before entering Johnson's apartment, satisfying the rule's requirements. 3. The court determined that the brief delay in Johnson's response to the knock and announcement did not render the entry unreasonable under the Fourth Amendment. 4. The court held that suppression of evidence is an "extreme sanction" and is not automatically required for every technical violation of the "knock-and-announce" rule. 5. The court affirmed the district court's denial of the motion to suppress, concluding that the officers' actions were constitutional.

Q: What cases are related to United States v. Shaheem Johnson?

Precedent cases cited or related to United States v. Shaheem Johnson: Wilson v. Arkansas, 514 U.S. 927 (1995); Richards v. Wisconsin, 520 U.S. 385 (1997); Hudson v. Michigan, 547 U.S. 586 (2006).

Q: What is the "knock-and-announce" rule?

The "knock-and-announce" rule, derived from common law and codified in federal statute (18 U.S.C. § 3109), requires law enforcement officers to announce their presence and purpose before forcibly entering a premises to execute a warrant, unless exigent circumstances justify an unannounced entry.

Q: Did the Fourth Circuit find that the "knock-and-announce" rule was violated in this case?

No, the Fourth Circuit affirmed the district court's denial of the motion to suppress, finding that the "knock-and-announce" rule was not violated because officers announced their presence and purpose before entry.

Q: What reasoning did the Fourth Circuit use to justify its decision regarding the "knock-and-announce" rule?

The court reasoned that the officers adequately announced their presence and purpose before forcibly entering Johnson's apartment. They also considered the brief delay in Johnson's response and determined it did not necessitate suppression of the evidence.

Q: What was the standard of review applied by the Fourth Circuit?

The Fourth Circuit reviewed the district court's denial of the motion to suppress, which typically involves a mixed standard of review: factual findings are reviewed for clear error, and legal conclusions, such as the application of the "knock-and-announce" rule, are reviewed de novo.

Q: What is the consequence of violating the "knock-and-announce" rule?

The primary consequence of violating the "knock-and-announce" rule is the suppression of any evidence obtained as a result of the illegal entry, under the exclusionary rule.

Q: Did the court consider the time delay between the announcement and entry?

Yes, the court considered the brief delay in Shaheem Johnson's response to the officers' announcement and determined that this delay did not rise to a level requiring suppression of the evidence found.

Q: What specific statute governs the "knock-and-announce" rule in federal cases?

The "knock-and-announce" rule in federal cases is primarily governed by 18 U.S.C. § 3109, which outlines the requirements for officers executing a search warrant.

Q: What was the district court's ruling that the Fourth Circuit affirmed?

The district court denied Shaheem Johnson's motion to suppress the evidence obtained from his apartment, finding that the officers complied with the "knock-and-announce" rule.

Q: What is the exclusionary rule and how does it relate to this case?

The exclusionary rule is a judicially created remedy that prohibits the use of illegally obtained evidence in a criminal trial. In this case, Johnson sought to invoke it, arguing the "knock-and-announce" violation rendered the seized evidence inadmissible.

Q: How does United States v. Shaheem Johnson affect me?

This decision reinforces that the "knock-and-announce" rule is not a rigid mandate for a specific waiting period, but rather a flexible standard of reasonableness. It clarifies that minor delays in occupant response, without more, will not automatically trigger the exclusionary rule, providing guidance to law enforcement on warrant execution. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.

Q: Who is affected by the Fourth Circuit's decision in United States v. Shaheem Johnson?

This decision directly affects Shaheem Johnson by allowing the evidence against him to be used in court. More broadly, it impacts individuals subject to search warrants and law enforcement agencies executing them, clarifying the application of the "knock-and-announce" rule.

Q: What is the practical implication of this ruling for law enforcement?

The ruling reinforces that a brief delay in a suspect's response after officers announce their presence and purpose does not automatically invalidate a search or require suppression of evidence, provided the announcement itself was proper.

Q: Does this ruling change how police must execute search warrants?

The ruling does not fundamentally change the requirements of the "knock-and-announce" rule but clarifies that minor delays in suspect response after proper announcement are unlikely to lead to suppression.

Q: What are the potential consequences for Shaheem Johnson following this decision?

Since the evidence was deemed admissible, Shaheem Johnson will likely face prosecution based on the evidence seized from his apartment, as his motion to suppress failed.

Q: How might this case influence future legal challenges to search warrants?

Future challenges based on the "knock-and-announce" rule may need to demonstrate more than just a brief delay in response after a proper announcement to succeed in suppressing evidence.

Q: How does this decision fit into the broader legal history of Fourth Amendment protections?

This decision is part of a long line of cases interpreting the Fourth Amendment's protection against unreasonable searches and seizures, specifically refining the application of the "knock-and-announce" requirement, which has roots in English common law dating back centuries.

Q: Are there historical exceptions to the "knock-and-announce" rule?

Yes, historically, exceptions to the "knock-and-announce" rule have been recognized in situations where officers reasonably believe announcing their presence would be dangerous, lead to the destruction of evidence, or permit the escape of the suspect (exigent circumstances).

Q: How does this case compare to other landmark Supreme Court cases on search and seizure?

While not a Supreme Court case, this decision aligns with Supreme Court precedent that balances Fourth Amendment rights with law enforcement needs, often requiring suppression only when there's a clear constitutional violation, as seen in cases like Wilson v. Arkansas which established the rule's constitutional basis.

Q: What was the docket number in United States v. Shaheem Johnson?

The docket number for United States v. Shaheem Johnson is 23-6896. This identifier is used to track the case through the court system.

Q: Can United States v. Shaheem Johnson be appealed?

Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.

Q: How did this case reach the Fourth Circuit Court of Appeals?

The case reached the Fourth Circuit on appeal after Shaheem Johnson was unsuccessful in his motion to suppress evidence in the district court. He appealed that denial, leading to the Fourth Circuit's review.

Q: What procedural step did Shaheem Johnson take that led to this appeal?

Shaheem Johnson filed a motion to suppress the evidence seized from his apartment, arguing it was obtained in violation of the "knock-and-announce" rule. When the district court denied this motion, he appealed that denial.