 English common law has required law enforcement to knock-and-announce since at least "Semayne's case" (1604), and in "Miller v. United States" (1958), the Supreme Court of the United States recognized that police must give notice before making a forced entry.In the U.S. federal criminal law, the rule generally requiring knock-and-announce is codified at 18 U.S.C § 3109.However, in "Wilson v. Arkansas" (1995) the Court created an exception to prevent the destruction of evidence and in "Hudson v. Michigan" (2006) the Court, by a 5–4 vote, held the exclusionary rule does not require the suppression of evidence police seize during an illegal forced entry.