Brumfield v. State

LUMPKIN, V. P.J.: concur in part, dissent in part.

T1 I concur with the outcome the Court reaches today, insofar as it affirms Appellant's conviction and sentence for Aggravated Manufacture of a Controlled Dangerous Substance and reverses Count II, following the State's concession of error. However, I dissent to the Court's reasoning, which includes lengthy dicta on proposition one concerning the "knock and announce" issue and a so-called "more expansive" interpretation of our state statutes and constitution than that available vis-a-vis the federal constitution's fourth amendment. I find these eight pages of dicta are not only unnecessary, but are also wrong, confusing, and in the long run counterproductive to our overall jurisprudence.

T2 As this Court in Long1 and DeGraff2 long ago recognized, the substance of Article 2, § 30 is "identical" to that of the Fourth Amendment to the U.S. Constitution, the former being "almost an exact copy" of the latter. For that reason this Court has consistently interpreted these provisions as two sides of the same coin.3

13 Historically, we could have originally interpreted our state constitution different than the U.S. Constitution, but we did not. Our jurisprudence now binds us to that interpretation. If we are to adhere to the concept *841of the "Rule of Law", then we must be consistent in the application of the law as formulated through its historical development.

T4 While the Oklahoma Supreme Court's decision in Turner v. City of Lawton4 may be interesting, in the law review sense, it has little or no relevance to the case before us.5 The decision, insofar as the eriminal law is concerned, is pure dicta. Moreover, the state Supreme Court failed to acknowledge or apply this Court's consistent interpretation of Art. 2, § 80 being in line with the Fourth Amendment, an interpretation that dates back to statehood.6 Thus, the Court missed or disregarded the historical development of our Constitutional interpretation in criminal cases. Using that case here, then, is an exercise in futility.

T5 Indeed, the opinion admits its lengthy analysis of the exclusionary rule is dicta, i.e., "we need not decide whether the search of Mr. Brumfield's home violated Oklahoma law or whether such a violation necessarily requires that the evidence discovered in the subsequent search be suppressed." The opinion then proceeds to find the alleged error was waived.7

T6 In my opinion, however, the case can be disposed of under the statute on the basis that officers knocked and announced their presence, but were refused admittance. 22 ©.S$.2001, § 1228(1).

. 1985 OK CR 119, 115-6, 706 P.2d 915, 916-17.

. 1909 OK CR 82, 2 Okl.Cr. 519, 528, 103 P. 538, 541 (1909).

. See my writings on similar claims in Harris v. State, 1989 OK CR 15, ¶ 2, 773 P.2d 1273, 1275; Dennis v. State, ¶ 2, 1999 OK CR 23, 990 P.2d 277, 287.

. 1986 OK 51, 733 P.2d 375.

. More interesting, however, is how today's opinion would use a twenty-year old decision from a state court with no criminal jurisdiction to maneuver around Hudson v. Michigan, - U.S. --, 126 S.Ct. 2159, 165 L.Ed.2d 56, a 2006 decision of the highest court of the land.

. Indeed, while citing to three of our cases, the Oklahoma Supreme Court was simply arguing that we had adopted the exclusionary rule, in light of U.S. Supreme Court decisions construing the Fourth Amendment. Those U.S. Supreme Court decisions did not end in 1986, but have continued, as demonstrated by Hudson v. Michigan.

. Because the issue raised is disposed of on waiver, the opinion's discussion of the "knock and announce" rule, resolves nothing in the case and is as pertinent to our appellate jurisdiction as my own thoughts on, say, pop culture.