In Hudson v. Michigan, 547 U.S. 586, 126 S. Ct. 2159, 165 L. Ed. 2d 56 (2006), police violated the knock-and-announce rule by entering a home too quickly (three to five seconds) after announcing their presence when executing a search warrant for drugs and firearms. 547 U.S. at 588. Hudson argued the entry violated his Fourth Amendment rights and that the seized evidence must be suppressed. Id. The Court disagreed, holding that the knock-and-announce violation was too attenuated from the seizure of evidence to justify suppression. Id. at 594. There was a valid search warrant, and the challenged entry was merely an "illegal manner of entry" or a "preliminary misstep," distinct from the subsequent seizure of evidence. Id. at 592. The Court explained: Until a valid warrant has issued, citizens are entitled to shield "their persons, houses, papers, and effects," from the government's scrutiny. Exclusion of the evidence obtained by a warrantless search vindicates that entitlement. The interests protected by the knock-and-announce requirement are quite different-and do not include the shielding of potential evidence from the government's eyes. Id. at 593.