The Court ruled in Wilson v. Arkansas (1995) that “in some circumstances an officer’s unannounced entry into a home might be unreasonable under the Fourth Amendment.” Justice Clarence Thomas examined the state of the common law during the time of the Founders, noting that “the common-law knock and announce principle was woven quickly into the fabric of early American law.” The Court did not say that a law enforcement official must knock and announce his or her presence before every search. Rather, the Court said that the failure to knock and announce is a relevant factor in determining whether a search is reasonable. This means that officers may be able to establish special factors showing that it was reasonable to engage in an unannounced entry.