Alan Shelby, a convicted felon serving concurrent federal and state sentences in Oregon, escaped from a Tillamook County Sheriff's vehicle by slipping out of his handcuffs and knocking over a deputy on November 1, 1994.

Three years before, he attempted escape by assaulting an officer, kicking open a jail door, carjacking a woman, and ramming into a police vehicle.

After authorities distributed press releases, a confidential informant told the ATF on November 3 that he had seen a man resembling Shelby at Hernan Ramirez's home in Boring, Oregon.

The United States Court of Appeals for the Ninth Circuit upheld the suppression by elaborating that property destruction requires specific instances of exigency that were not met.

The Court cited Richards v. Wisconsin as precedent that while there is no blanket exception to the knock-and-announce rule, a no-knock warrant is justifiable if there is a high chance of physical threats or tampering of valuable evidence.