and violated his Fourth Amendment rights against unreasonable searches and seizures. In particular, he alleged that the officers failed to announce that they were there to execute a warrant and that they did not wait for a reply to their knocks before forcibly entering his residence. Based upon these allegations, Reynoso met his initial burden of making a showing that his Fourth Amendment rights were violated by the officers’ alleged failure to properly announce their purpose and to wait a reasonable length of time before entering under color of warrant. Thus, at the suppression hearing, the State had the burden to show that the officers’ actions were reasonable. See Holmes, 175 F.Supp.2d at 73-76; of. Richards v. Wisconsin, 520 U.S. 385, 394-395, 117 S.Ct. 1416, 137 L.Ed.2d 615 (1997) (<HOLDING>); United States v. Hawkins, 139 F.3d 29, 32
holding that notwithstanding the officers testimony that he had no suspicion of criminality the officer was aware of facts that would give rise to reasonable suspicion in the mind of a reasonable officer holding that suspicion must be individualized holding noknock entry justified where officers had reasonable suspicion that entering drug stash house would be dangerous and drug dealer frequenting house could not be found elsewhere holding that it would be clearly unreasonable to deny a police officer the ability to neutralize the threat of physical harm if he has reasonable suspicion that a suspect is armed and dangerous holding that when noknock entry is challenged police must prove they had a reasonable suspicion that knocking and announcing presence would be dangerous or futile or inhibit effective investigation of crime