Tatman v. State
In Tatman v. State, 320 A.2d 750 (Del.1974), the police had a search warrant for a second floor apartment. They arrived at the building at approximately 6:00 a.m.; they knocked at the locked front door and, after approximately five seconds, forced the door open.
They then went to defendant's apartment, battered down the door and entered with guns drawn. Defendant and a companion were asleep. It was in that context that the court concluded that the knock on the building's outer door was ineffective because it failed to provide any realistic potential of notifying the occupants of the apartment of police presence.
The court concluded that, in consequence, the police were required to knock again on the door of defendant's apartment before entering; it was the failure of the police to do so that led to the court suppressing the evidence recovered from that apartment.