In Louisiana, it took a judge just a few clicks
online to give West Baton Rouge Parish deputies the go-ahead to force their way
into a motel room without knocking. Within 30 minutes, officers rushed in and
fatally shot an unarmed Black man, seizing a little more than 22 grams of
methamphetamine, marijuana, cocaine and hydrocodone, reported the Washington Post.
In St. Louis, a judge authorized police to break
down the doors of three homes simultaneously without knocking. Officers killed
a 63-year-old Black grandfather, and police said they found just over nine
grams of heroin, marijuana, fentanyl and hydrocodone in the three homes
In Houston, a judge approved scores of requests
for no-knock warrants for officers who relied on unnamed
informants. One raid led to a gun battle that left a White man and
woman dead and four officers shot, and it failed to turn up the heroin
police said they would find. The officer who requested the warrant later
admitted he fabricated the confidential informant.
Judges and magistrates are expected to review
requests for no-knock warrants — one of the most intrusive and dangerous
tactics available to law enforcement — to ensure that citizens are protected
from unreasonable searches, as provided in the Fourth Amendment to the
But judges generally rely on the word of police
officers and rarely question the merits of the requests, offering little
resistance when they seek authorization for no-knocks, a Washington Post
investigation has found. The searches, which were meant to be used sparingly,
have become commonplace for drug squads and SWAT teams.
Criminal justice experts estimate that police carry
out tens of thousands of no-knock raids every year nationwide, mostly in
drug-related searches. But few agencies monitor their use, making the exact
number unknown. None of the 50 state court systems or the District of Columbia
reported tracking the use of no-knock warrants. And no federal or state
government agencies keep tabs on the number of people killed or wounded in the
“The whole system has devolved into a perfunctory
bureaucracy that doesn’t take any care or due diligence for how it’s done,”
said Peter Kraska, an Eastern Kentucky University professor who has studied
no-knock raids for more than three decades. “That wouldn’t be as big of a
deal, except that we’re talking about a really extreme policing approach —
breaking into people’s homes with a surprise entry with the possibility of
The raids became a flash point two years ago when
Louisville police killed 26-year-old Breonna Taylor inside her apartment
as part of a drug investigation involving an ex-boyfriend who didn’t live
there. In that case, an officer obtained no-knock warrants for Taylor’s home
and four other residences. Police later said they knocked and announced
themselves at Taylor’s home, a claim that has been disputed. In a no-knock raid
in February, Minneapolis police shot and killed 22-year-old Amir Locke. Body-camera footage
shows Locke, who was not the target of the investigation, wrapped in a blanket
on a couch with a gun in his hand when police shot him.
Police carrying out 21 no-knock warrants have killed
at least 22 people across the country since 2015, according to a review of The
Post’s database of fatal shootings by police and hundreds of
court records. In one case, an officer was also killed.
Of the 22 people fatally shot during no-knock raids
since 2015, 13 were Black or Hispanic. Experts have suggested that high-risk
searches disproportionately target Black and Hispanic homes.
In the vast majority of the cases, police said they
were searching for illegal drugs and expected the subjects to be armed.
In all but two of these raids, police claimed they
encountered someone who had a weapon — in most cases a gun. In at least five
raids, police killed someone who was not a focus of the warrant, according to
court records and media reports.
The Post obtained documents listing evidence for 13
of the fatal raids: In 12, officers recovered less than three pounds of drugs
combined — including marijuana, mushrooms and heroin. Only one raid recovered
more: In 2018 in Fort Worth, officers found more than a pound of marijuana,
three pounds of mushrooms and more than 16 pounds of a prescription allergy
medicine. Officials did not respond to a request for or declined to
provide a list quantifying the drugs seized in the other eight raids.
The full tally of fatalities from no-knock warrants
is unknown: The Post database includes at least 24 other searches that ended in
fatal shootings of civilians, but court officials and police departments were
unable or declined to provide records clarifying whether the raids involved
no-knock warrants. In 2017, the New York Times examined SWAT team raids and
found that at least 81 civilians and 13 officers had died from 2010
through 2016 in searches that involved both no-knock warrants and
In recent years, it has become quicker and easier
for judges to approve no-knock warrants, bypassing the normal process that
usually involves an officer meeting with a judge in person. Software,
adopted by hundreds of law enforcement agencies, allows judges to remotely
approve requests using computers, cellphones or tablets.
The Post reviewed more than 2,500 warrants in 30
states, examined court and police records, and interviewed dozens of
judges, police officials, lawmakers, witnesses and relatives of people who
died in raids.
Officers obtaining typical search warrants are
required to show a judge they have probable cause, listing the location to be
searched and the contraband or evidence they expect to find. They’re also
supposed to “knock and announce” before entering homes.
But with a no-knock warrant, police can force their
way into a home without warning. The requirements for no-knock warrants may
vary by jurisdiction, but are generally guided by a 1997 Supreme Court opinion involving a forced-entry
search by police. The court ruled that police seeking to conduct these searches
must have a “reasonable suspicion” why knocking and announcing could be
dangerous or result in the destruction of evidence. Police are generally
expected to make this argument to judges when seeking approval for a no-knock
“This showing is not high, but the police should be
required to make it whenever the reasonableness of a no-knock entry is
challenged,” the justice wrote.
Training and educational requirements for judges
vary state to state. In some cases, judges or magistrates without law
degrees or extensive training are tasked with approving no-knocks.
“It’s set up so that police departments can do
whatever they want with regards to no-knocks,” Kraska said.
Across the country, 29 states and 21 cities
have approved legislation or ordinances restricting the use of no-knocks,
according to Campaign Zero, a police reform group. At least 13 other states and
nine other cities have recently considered proposals for such
restrictions, the group said.
In Maryland, after Montgomery County Police killed a
man in a no-knock raid, the council in 2020 imposed limits on such
warrants. Police reported that 108 of 140 search warrants
executed by the SWAT team in 2019 were no-knocks.
In South Carolina, Chief Justice Donald W.
Beatty ordered a temporary ban on no-knocks in 2020 after a
survey by the state court system revealed that magistrates routinely issued
warrants without questioning police, and that most “do not understand the
gravity of no-knock warrants and do not discern the heightened requirements for
issuing a no-knock warrant.”
But many judges say that in evaluating the requests
for search warrants, they rely on the officers’ claims in the affidavits
because they are filed under oath.
Gordon Marcum, a former municipal judge who approved
the no-knock warrant for the 2019 deadly raid in Houston, told The Post in an
interview that he considered himself the last line of defense against
unjustified searches and carefully scrutinized the warrants he handled. But he
said it wasn’t his responsibility to spot patterns, including whether officers
appeared to be lying on affidavits or whether police failed to locate the guns
or drugs they claimed they would find. Though officers typically must file
documents with the court detailing what they seized in raids, judges who sign
the warrants aren’t required to examine them.
“It wasn’t my job to do that,” Marcum said. “It’s
the officer who’s in charge. The police officer, the supervisor, the captain,
the department director, and all of them who have access to those things.”
Police defending these warrants note that the vast
majority of them lead to no injuries and are likely to have prevented violence
and preserved evidence that otherwise would have been destroyed.
Patrick Yoes, national president of the Fraternal
Order of Police, said there are misconceptions about no-knocks, including that
police use them frequently and haphazardly. “In reality, there’s a whole lot of
assessment that goes into determining whether a no-knock warrant is going to be
executed,” Yoes said.
The raids can be deadly not only for residents,
but officers as well.
One Texas man, Marvin Guy, is facing charges,
including capital murder, after an officer was killed and three others were shot during
a 2014 no-knock raid at his home in Killeen. Guy was sleeping when
officers smashed his window and slammed a battering ram into his front door. He
said he thought he was being robbed and fired a gun through the broken
window. Police had suspected that Guy, who had an extensive criminal history,
was selling drugs, but no drugs were found in his home. Police said they found
trace amounts of a white powder in his car, records show.
Survivors of raids have said they feared that
intruders were breaking into their homes. In Louisville, Breonna Taylor’s
boyfriend said he fired at police because he didn’t know who was storming
Tamika Palmer, Taylor’s mother, said she blames the
judge who signed the warrant that led to her daughter’s death as much as she
blames the police.
“We know that [police] are not doing the work to get
these warrants, that they’re not doing what needs to be done,” she said. “Why
would you want to sign your name on that? Why wouldn’t you want to make sure,
‘Let me just take a day or two to make sure you’ve done what you need to.’ …
It’s insane, it’s lazy.”
On Feb. 21, 2017, a boom shook Marlon O’Neal from
his sleep in his basement bedroom in south St. Louis. Panicked and
half-dressed, he told his girlfriend to hide in the closet. She yelled for her
4-year-old son, who was sleeping near the front door.
O’Neal, thinking intruders had broken in, said he
crept up the steps and saw red lasers from gun sights aimed at the living room
wall. He realized the men, clad in dark clothing, were police. Officers yelled
at him to go outside, where police SUVs lined California Avenue.
A SWAT team had already raided his neighbor’s home
two doors down. Now, the team of 17 officers converged and headed to a third
house next to O’Neal’s home.
Inside was his former father-in-law: 63-year-old Don
Clark, known as “Pops.” He was hard of hearing, couldn’t see well and
walked with a cane. He slept in a bed near the front door.
Officers smashed a battering ram into Clark’s front
door and tossed a flash-bang device inside, according to witness statements and
police records. Nicholas Manasco, the first officer in, later told an
investigator that Clark shot at him — he said he felt a bullet whiz past
him and in the darkness saw someone holding a gun. Manasco shot at Clark,
hitting him nine times. He was pronounced dead at a hospital.
O’Neal was not arrested or charged in connection
with the raid.
The deadly raid was one of many in which judges gave
St. Louis police the go-ahead to target multiple homes simultaneously with
In the raid on California Avenue, police initially
sought to search two addresses; they added Clark’s home two days later, records
show. The affidavits were identical for all three homes.
Detective Thomas Strode of the St. Louis
Metropolitan Police Department accused Clark and others of conducting drug
sales and storing weapons and narcotics in homes on California Avenue. In his
affidavit, Strode said he also did several weeks of surveillance. He reported a
controlled drug buy, but it happened five months earlier and about a mile away
from California Avenue, according to the affidavit.
Strode noted in his affidavit that some of the
residents of the targeted homes had criminal histories: “Since the targets of
the investigation are known to be armed narcotic traffickers, many of whom have
a violent history, I am requesting no-knock search warrants” for the three
O’Neal, who lived next to Clark, had felony
convictions, including unlawful possession of a firearm in 2010. Ben Byas,
another neighbor, was on probation for possession with intent to distribute
drugs. And Strode said in the affidavit that Clark had arrests for unlawful use
of a weapon, felonious restraint and assault. A Post review of local court
records showed Clark, who once owned a security company, had no charges or
On the morning of the raid, Associate Circuit Court
Judge Barbara Peebles signed the warrants.
A court spokesman said Peebles determined there was
probable cause “based on the information presented under oath.” Peebles, now
a judge in the juvenile court, declined to comment further.
From 2016 through 2018, Strode received approval for
at least 43 no-knock warrants, according to a Post analysis of records obtained
by ArchCity Defenders, a legal advocacy group helping to represent Clark’s
family in a wrongful-death lawsuit filed against the police.
Twenty-four of the warrants involved multi-house raids.
In nearly half of those 43 raids for which Strode
received approval, officers said they failed to find suspected drugs, according
to a review of documents filed in court by police.
Police need a judge’s approval to raid a home or
business without warning. These are high-risk searches that require additional
scrutiny — but a Post investigation found that judges rarely question the
merits of these requests by police. This affidavit from a 2017 raid by the St.
Louis Metropolitan Police Department shows how police obtained no-knock
warrants to raid three homes.
Strode did not respond to messages seeking comment.
Evita Caldwell, a police spokeswoman, said Strode and Manasco, the officer who
fatally shot Clark, no longer work at the St. Louis police department and
declined to discuss the terms of their departures. More than five years later,
the department and the circuit attorney said they are still investigating
the fatal shooting.
Police rely heavily on confidential informants, but
experts said they can be unreliable — incentivized to trade questionable
information for reduced sentences or other beneficial treatment.
David Moran, a University of Michigan law professor
who argued before the Supreme Court in a case about evidence seized during
no-knocks, said a raid on one home can easily become a violent confrontation.
Carrying out simultaneous no-knock warrants at several homes “just multiplies
the risk,” he said.
That risk takes on a new dimension in states with
high gun ownership or “stand your ground” laws, including Missouri. In those
states, people may legally defend themselves with deadly force if they believe
their life is in danger.
Clark had moved into his home a few years earlier
and was concerned about crime, his family said.
Sherrie Clark-Torrence, one of Clark’s daughters,
said that she doesn’t believe her father used a gun as police claimed, but even if
he had, it would have been self-defense. In the family’s lawsuit, they allege that he was
unarmed, that he had no criminal convictions and police lied about
surveillance of his home.
“He’s already an elderly man in a bad neighborhood,”
she said in an interview. “So if he heard a boom and he grabbed his revolver …
to protect himself, wouldn’t that be right?”
The city of St. Louis declined to comment, citing
the pending lawsuit.
Police said they recovered a .45 caliber Glock
handgun, a 9mm Taurus handgun and boxes of ammunition from Clark’s home. A
forensics report concluded that one gun had been fired.
Clark’s family disputes that he had any drugs, according
to their lawsuit.
At Clark’s home, officers reported finding 8.39
grams of heroin and 0.50 grams of marijuana. They also said they found 20
pills; a lab test determined one to be .005 grams of hydrocodone.
At the home of Ben Byas, police said they recovered
0.1 grams of fentanyl, .08 grams of heroin and fentanyl, and a plastic bag with
an unknown white substance.
After the raid, Byas told police he had heroin and
cocaine in his home. When a detective asked if he sold them, Byas responded,
“No I just pretty much use.” He was arrested, but wasn’t charged.
Police said they seized no drugs at O’Neal’s home.
He and his girlfriend claimed officers stole money from a safe in his basement.
He questioned whether the raids were worth it.
“You did all these search warrants, and that’s all
you found in this house,” he said, referring to Clark’s home. “What about my
house? What did you find there? … You know, not nothing.”
On a humid afternoon in July 2019 in Port Allen,
La., the River West Narcotics Task Force sent a confidential informant to buy
$50 worth of methamphetamine from a suspected drug dealer at the Budget 7
Motel, sandwiched between a gas station and another motel near the Mississippi
The quick transaction in room No. 5 was enough
evidence for West Baton Rouge sheriff’s Deputy Brett Cavaliere to request
a no-knock warrant.
Cavaliere filled out the request in his office,
using software called CloudGavel. The affidavit was barely four pages
long, mostly filled with Cavaliere’s law enforcement experience and boilerplate
He typed in one sentence about the suspect: “Affiant
states in the last 72 hours, an informant purchased a quantity of
methamphetamine during a controlled operation from a Black male at the Budget 7
Motel Room #5.” He didn’t include the suspect’s name, whether he had a gun or
who else was in the room.
At 6:06 p.m., with the click of a button, the deputy
sent the request to Tonya Lurry, a West Baton Rouge judge, for approval:
“Affiant has requested and cause has been shown for the authorization of a ‘NO
KNOCK’ entry or entry without announcement to search the aforesaid premises,”
At 6:17 p.m., Lurry electronically signed it,
records show. It’s unclear whether Lurry spoke with the deputy or how much time
she spent considering the request.
About 6:40 p.m., Cavaliere approached the motel room
with Deputy Vance Matranga and two other West Baton Rouge sheriff’s deputies.
Jessica Clouatre told The Post she was on the bed inside,
watching a YouTube video. Her 38-year-old fiance, Josef Richardson, had just showered,
and she said he opened the door a crack to let out cigarette smoke. The couple
was staying at the motel while searching for a new apartment, and had hosted
Richardson’s daughters the day before.
He had a criminal record that included felony
convictions for resisting arrest and battery of an officer, and he was on
parole after pleading guilty in 2017 to possession with intent to sell drugs.
He looked tough with tattoos and gold teeth, but his friends and family knew
him as a father of three who enjoyed taking his children shopping and to water
Clouatre said she looked up as deputies rushed in
and yelled “sheriff’s office!” She said both she and Richardson had their hands
up when one deputy bent Richardson’s arm and brought him to the ground. Within
seconds, she said, Matranga had shot Richardson in the back of the neck.
The deputies involved in the raid told a state
police investigator that there was a struggle between Cavaliere and Richardson.
One deputy said he holstered his gun to help Cavaliere, and Matranga said he
fired his gun after seeing Richardson pull out a dark object from the waistband
of his shorts, according to interviews with investigators.
But Richardson was unarmed: He was holding a bag of
drugs, according to an attorney general’s report. Officers arrested
Clouatre, and Richardson died at the scene.
Officers said they recovered about 9 grams of
methamphetamine, 9 grams of marijuana, 4.4 grams of cocaine and a few pills
“Anybody selling drugs out of the Budget 7 Motel is
not a major player,” said Ron Haley, an attorney representing Richardson’s
children in a wrongful-death lawsuit against the sheriff’s office.
The state attorney general ruled the killing was justified. Cavaliere, who is now a
lieutenant, did not return requests for comment.
In an interview with The Post, Matranga declined to
discuss most details of the case. Matranga, who is now a corporal in the
department, also defended Cavaliere, saying he is a “meticulous and thorough”
officer. And he said he believed Richardson could have been armed because of
his “extensive criminal history.”
Deputies found no weapons in his motel room.
The family questions the basis for the deadly raid.
Lurry, who approved the warrant, was elected as a
judge 15 months before Richardson’s shooting after a career as a public
defender and prosecutor. She declined repeated requests for comment.
For years, Louisiana has been a leader in
“e-warrants,” warrants that are processed electronically on computers,
smartphones and other tablets. CloudGavel, the Baton Rouge software company
used by the sheriff’s office, said its technology is used in nine states by
more than 200 agencies, including police in Austin and New Orleans. The number
of all types of warrants processed annually increased from 13,000 to almost
90,000 over the past six years. The company declined to say how many of those
were no-knock warrants.
CloudGavel markets its software by emphasizing its
efficiency, using the tag line “Serves justice. Saves time.” An information
sheet on its website proclaimed: “The one that got away? Not this time.
When officers use CloudGavel’s Electronic Warrant Solution, warrant processing
can happen up to 90% faster.”
Around the time of Richardson’s death, CloudGavel
touted that it took about 27 minutes from warrant submission to approval. Cavaliere
and Lurry beat that by 16 minutes.
Casey Roussel, CloudGavel’s president and chief
customer officer, said law enforcement likes the technology because it saves
time and money. He also said that the software allows courts to gather more
data about warrants.
“The technology is not giving them the ability to
more easily get no-knock warrants,” he said. “We’re eliminating the drive to
and from the judge. At the end of the day, whether it’s a paper warrant or a
digital warrant, one hundred percent of the responsibility relies on the
But some criminal justice advocates worry that
judicial scrutiny is being compromised for efficiency, said the Rev. Alexis
Anderson, a member of the East Baton Rouge Parish Prison Reform Coalition. The
organization sends volunteers to monitor bail hearings in Baton Rouge.
“While the technology certainly speeds up the
process, what gets lost sometimes is the due process in that speed,” she said.
“Because we’re assuming, quite frankly, that great thought is given to these
warrants … and sometimes that’s not true.”
Richardson’s children, as well as Clouatre, have
sued the West Baton Rouge Sheriff’s Office over the raid. That case is pending.
Clouatre is facing felony charges of possession with
intent to distribute drugs from that night at the motel. She has pleaded not
The warrant did not name Clouatre, who said she
is haunted by the raid.
“To this day, I cry every day and I’m traumatized,”
Houston Judge Gordon Marcum was watching television
at home in his gated community on Jan. 28, 2019, when he learned about a deadly
no-knock raid across town. Immediately, he knew that he had signed the search
Just hours before the raid on a house on Harding
Street, Houston police officer Gerald Goines had requested Marcum approve a
no-knock warrant, claiming a confidential informant purchased an unspecified
quantity of heroin at the house in a low-income, largely Latino neighborhood in southeast
Houston. The narcotics officer didn’t list the name of the suspected dealer,
information that is not required.
Shortly before 5 p.m., members of Narcotics Squad 15
descended on the home of Dennis Tuttle and Rhogena Nicholas, forcing open
the front door and fatally shooting their pit bull. Officers shot and killed
Tuttle and Nicholas in their living room.
Police claimed that Tuttle was armed with a
.357-magnum revolver and shot first. Four officers, including Goines, were shot
during the gun battle. One was permanently paralyzed.
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