Rush, C.J.
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A long-time confidential informant saw Mario Watkins in his Evansville home with a gun, cocaine, and marijuana. After receiving this tip, Evansville police got a search warrant, surveilled the house, and decided to send in the SWAT team. The team met to plan the warrant execution, taking into account the layout of the house, Watkins’s violent criminal history, and the danger posed by four adults with narcotics and a gun.
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Searching the house, officers found a plate with crack cocaine residue, digital scales, 4.2 grams of crack cocaine, 706 grams of marijuana, 35 hydrocodone pills, 21 alprazolam pills, 25 oxycodone pills, $263 in cash, and a .40 caliber Hi-Point handgun.
The State charged Watkins with multiple felonies. He filed a motion to suppress, arguing that the search warrant was unsupported by probable cause under the Fourth Amendment and that its execution violated the search-and-seizure protections of the Fourth Amendment and Article 1, Section 11 of the Indiana Constitution. The trial court denied the motion.
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Watkins appealed, arguing that the search warrant affidavit did not establish probable cause in violation of the Fourth Amendment and that the search warrant execution was unreasonable under Article 1, Section 11 of the Indiana Constitution. A split panel of the Court of Appeals reversed. The majority found the search unreasonable under Article 1, Section 11’s Litchfield test because “the extent of law enforcement needs for a military-style assault was low and the degree of intrusion was unreasonably high.” Watkins v. State, 67 N.E.3d 1092, 1102 (Ind. Ct. App. 2017). Judge May dissented, as she would have found the search reasonable under the totality of the circumstances. Id. at 1102 (May, J., dissenting).
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Watkins challenges the constitutionality of the warrant execution only under Article 1, Section 11 of the Indiana Constitution—an issue that we review de novo. Zanders v. State, 73 N.E.3d 178, 181 (Ind. 2017).
He then challenges the sufficiency of the search warrant affidavit only under the Fourth Amendment. …
The parties agree that the method of executing a search warrant triggers our State Constitution’s protections, but they dispute the proper test for determining whether that method is reasonable. We hold that the totality-of-the-circumstances Litchfield test—a test applied hundreds of times in our courts—remains well-suited to assess reasonableness under Article 1, Section 11. See Simons v. Simons, 566 N.E.2d 551, 557 (Ind. Ct. App. 1991) (“If it ain’t broke, don’t fix it!”). …
The SWAT team’s search of Watkins’s home, then, must live up to our Constitution’s expectations—it must not be “unreasonable.” The parties disagree on how to determine reasonableness. Watkins asks us to stick with the totality-of-the-circumstances test we established in Litchfield v. State, 824 N.E.2d 356, 359–61 (Ind. 2005). The State argues that Litchfield shouldn’t apply to search warrant executions and proposes a new test: search warrant executions should be unreasonable only if “no reasonable officer” would execute a search that way.
We agree with Watkins that the Litchfield test remains well-suited to assess the reasonableness of search warrant executions, making any new test unnecessary. This totality-of-the-circumstances test is our “faithful stand-by” to determine reasonableness under our Constitution, Zanders, 73 N.E.3d at 186, and is appropriate for a range of contexts, see Garcia v. State, 47 N.E.3d 1196, 1199 (Ind. 2016). …
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Under the Litchfield test, we assess reasonableness under the totality of the circumstances, balancing “1) the degree of concern, suspicion, or knowledge that a violation has occurred, 2) the degree of intrusion the method of the search or seizure imposes on the citizen’s ordinary activities, and 3) the extent of law enforcement needs.” Carpenter, 18 N.E.3d at 1002 (quoting Litchfield, 824 N.E.2d at 361). …
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The Litchfield test continues to serve us well, so we decline the State’s invitation to replace it with an unprecedented “no reasonable officer” test for search warrant executions. Under the totality of the circumstances, the search warrant execution at Watkins’s house did not violate Article 1, Section 11 of the Indiana Constitution. And the search warrant affidavit survives our deferential Fourth Amendment review because it provided a substantial basis for the probable cause finding. We therefore affirm the trial court.
David, Massa, Slaughter, and Goff, JJ., concur.