Can police search YOUR home if they have an arrest warrant for someone else? Steagald v. US

Background of the Case

On January 14, 1978, a confidential informant told Detroit police that wanted drug dealer Ricky Lyons was at a home in Atlanta, Georgia. Atlanta police went to the residence and searched it without a warrant. The home belonged to petitioner Gary Steagald, not Lyons. Officers did not find Lyons but did discover what looked like cocaine. After that, police obtained a warrant and completed a search, ultimately seizing 43 pounds of cocaine.

What Happened Next

Steagald was arrested and brought to trial. He argued that the evidence police found before getting a warrant should be suppressed.

The Legal Question

Does the Fourth Amendment stop police from entering and searching the home of a third party, without a warrant, while looking for a suspect?

The Supreme Court’s Ruling

Yes. The Court held that the Fourth Amendment prevents all warrantless searches of homes unless there are exigent circumstances or consent. In this case, agents tried to use Lyons’s arrest warrant as permission to enter Steagald’s home. But that warrant only protected Lyons from an unlawful seizure. It offered no protection for Steagald’s privacy.

The Court explained that only a judge, not officers in the field, can make the decision to intrude into someone’s home. Without a search warrant, the entry and search violated Steagald’s Fourth Amendment rights.

📖 Read the full opinion here: Steagald v. United States, 451 U.S. 204 (1981)

About the Author

Anton Vialtsin, Esq.
LAWSTACHE™ LAW FIRM | Criminal Defense and Business Law
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