On January 14, 1978, a confidential informant contacted the Detroit police with information that wanted-drug dealer Ricky Lyons was at a residence in Atlanta, Georgia. Atlanta police responded to the residence and, without a warrant, searched the home of petitioner Gary Steagald. Although the police did not find Lyons, they did find what appeared to be cocaine. At this point, the police obtained a warrant and completed their search, in which they found 43 pounds of cocaine.
Steagald was arrested and brought to trial. He moved to suppress the evidence that police found prior to the warrants.
Does the Fourth Amendment prevent police officers from searching for a suspect in the home of a third party without obtaining a warrant?
Yes. The Court held that the Fourth Amendment prevents all warrantless searches of homes unless there are clearly exigent circumstances or consent. In this case, the agents sought to do more than use the warrant to arrest Lyons in public place or in his home; instead, they relied on the warrant as legal authority to enter the home of a third person based on their belief that Ricky Lyons might be a guest there. Regardless of how reasonable this belief might have been, it was never subjected to the detached scrutiny of a judicial officer. Thus, while the warrant in this case may have protected Lyons from an unreasonable seizure, it did absolutely nothing to protect petitioner’s privacy interest in being free from an unreasonable invasion and search of his home. Instead, petitioner’s only protection from an illegal entry and search was the agent’s personal determination of probable cause. In the absence of exigent circumstances, we have consistently held that such judicially untested determinations are not reliable enough to justify an entry into a person’s home to arrest him without a warrant, or a search of a home for objects in the absence of a search warrant.
Read full opinion here: Steagald v. United States, 451 U.S. 204 (1981)
Anton Vialtsin, Esq.
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