In State v. Ordonez-Villanueva, 138 Ore. App. 236, 908 P.2d 333 (Or. App. 1995), review denied, 322 Or. 644, 912 P.2d 375 (1996), police officers made a forcible entry into an apartment just four seconds after they knocked and announced that they had a search warrant.
The Oregon Court of Appeals held that the officers had acted reasonably because the search warrant authorized a search for controlled substances, which could easily have been destroyed if the officers were required to wait a prolonged time after their announcement. Id. at 336-37.