Steagald v. United States

In Steagald v. United States, 451 U.S. 204 (1981) DEA agents entered the home of the defendant, with an arrest warrant, looking for another named individual. Although the named individual was not found, in the course of searching the home, the DEA agents found cocaine and other evidence of illegal activity. Id. at 206-207. In That case, a federal drug enforcement agent had received information from a confidential informant concerning the possible whereabouts of Ricky Lyons, a fugitive wanted on federal drug charges. The informant furnished an Atlanta telephone number at which Lyons could be reached for the next twenty-four hours. Another agent obtained the corresponding address from the telephone company. That agent also determined that Lyons was the subject of a six-month-old arrest warrant. Two days later, a team of officers drove to the indicated address to search for Lyons. They observed the defendant and another man, Hoyt Gaultney, standing outside the house that was to be searched. The officers approached the men with guns drawn, frisked them and demanded identification, determining that neither was Lyons. Some of the agents went to the house. Gaultney's wife answered the door and told the agents she was alone in the house. She was placed under guard while one agent searched the house. Lyons was not found, but the agent saw some apparent cocaine. The agent in charge sent one of his officers to obtain a search warrant, but in the meantime conducted a second search of the house, which produced additional incriminating evidence. During a third search conducted with a search warrant, the agents discovered forty-three pounds of cocaine. The defendant was arrested and charged with violating federal drug laws. After his motion to suppress was denied, the defendant was convicted. A divided Fifth Circuit Court of Appeals affirmed the denial of the suppression motion. Id., 451 U.S. at 206-07. The Supreme Court reversed. Regarding defendant and the Gaultneys as the residents of the house, the Supreme Court saw the question posed as "a narrow one," id., 451 U.S. at 211, "whether an arrest warrant--as opposed to a search warrant--is adequate to protect the Fourth Amendment interests of persons not named in the warrant, when their homes are searched without their consent and in the absence of exigent circumstances." Id., 451 U.S. at 212. In discussing the conceptual background, the Court noted: While an arrest warrant and a search warrant both serve to subject the probable-cause determination of the police to judicial review, the interests protected by the two warrants differ. An arrest warrant is issued by a magistrate upon a showing that probable cause exists to believe that the subject of the warrant has committed an offense and thus the warrant primarily serves to protect an individual from an unreasonable seizure. A search warrant, in contrast, is issued upon a showing of probable cause to believe that the legitimate object of a search is located in a particular place, and therefore safeguards an individual's interest in the privacy of his home and possessions against the unjustified intrusion of the police. Id., 451 U.S. at 212-13. The Court observed that although the arrest warrant was a valid authorization to seize Lyons, it could not be used by law enforcement personnel "as legal authority to enter the home of a third person based on their belief that Ricky Lyons might be a guest there," because "regardless of how reasonable this belief might have been ... the warrant ... while protecting Lyons from an unreasonable seizure, ... did absolutely nothing to protect the defendant's privacy interest in being free from an unreasonable invasion and search of his home." Id., 451 U.S. at 213. The Court went on to state that neither the common law nor Fourth Amendment history provided any justification, in the factual context provided, for entry into a home based alone upon an arrest warrant for someone who did not reside there, id., 451 U.S. at 217- 20, absent consent or exigency, id., 451 U.S. at 221-22. A search warrant was required. Id., 451 U.S. at 222. The Steagald court held the search to be unreasonable. An arrest warrant naming one individual did not permit a search of another individual's home. Thus, for purposes of the search, the intrusion into the home was warrantless and absent consent or exigent circumstances, it was improper. Two distinct interests are implicated under these circumstances. First, the named individual's interest in being free from an unreasonable seizure; and second, the homeowner's interest in being free from an unreasonable search of his home. Id. The arrest warrant only addressed the former interest and did not cover the homeowner's residence. Id. Thus, the government's conduct was equivalent to a search without a warrant. Id. The Court held absent exigent circumstances or consent, law enforcement officers could not search for the subject of an arrest warrant in the home of a third party without a search warrant. Id. at 211-16. In so holding, the Court distinguished between the probable cause requirements for arrest and search warrants, and concluded "while the warrant in this case may have protected Lyons from an unreasonable seizure, it did absolutely nothing to protect Steagald's privacy interest in being free from an unreasonable invasion and search of his home." Id. at 213. In Steagald v. United States, the Court distinguished between the protections of the arrest and search warrants. "An arrest warrant is issued by a magistrate upon a showing that probable cause exists to believe that the subject of the warrant has committed an offense and thus the warrant primarily serves to protect an individual from an unreasonable seizure. A search warrant, in contrast, is issued upon a showing of probable cause to believe that the legitimate object of a search is located in a particular place, and therefore safeguards an individual's interest in the privacy of his home and possessions against the unjustified intrusion of the police." 451 U.S. at 213.