E.D.Mo.: Such is the risk of a no-knock warrant

“This case arises from an officer shooting the target of a search warrant. Detective Thomas Strode obtained a warrant to search Don Clark’s residence for illegal guns and drugs. As officers entered without knocking, Clark shot at the officers but missed. Officer Nicholas Manasco shot and killed Clark. Clark’s family sued Strode, Manasco, and the City of St. Louis, alleging violations of the Fourth Amendment, the Fourteenth Amendment, and state law. The officers and the City moved for summary judgment. None of the evidence Clark’s family submitted is sufficient to establish that Strode’s warrant lacked probable cause (and that he knew or should have known that), nor that a reasonable officer in Manasco’s position would have been required not to use deadly force. The Court grants the motion for summary judgment.” Clark v. City of St. Louis, 2026 U.S. Dist. LEXIS 30695 (E.D. Mo. Feb. 13, 2026).*