The Roberts Court narrowed the exclusionary rule—which excludes evidence that has been unconstitutionally seized by police—in Hudson v. Michigan. The Court narrowed the exclusionary rule by holding that it did not apply when the police failed to “knock and announce” their presence before searching a suspect’s home pursuant to a warrant. Justice Antonin Scalia, writing for a five-member majority, reasoned that the “knock and announce” rule “has never protected an individual from the government seeing evidence particularly described in a search warrant.” The dissenting justices contended that the majority ignored past Court decisions that protected the sanctity of privacy in the home.