Steele v. United States No. 1

Background

A man who leased a two-numbered commercial building that included a garage and storage space (referred to as Steele) challenged a search that found large quantities of whiskey. Two General Prohibition Agents watched a truck unload cases marked “whiskey” into the garage area, checked official records and found no permit for liquor, and then obtained a warrant from a U.S. Commissioner to search the garage, connected rooms, basement, and sub-cellar. The agents entered and seized hundreds of cases, bags, barrels, and bottles of liquor across floors connected by an elevator.

Reasoning

The Court addressed whether the warrant met the Fourth Amendment and statutory requirements and provided probable cause and a sufficiently particular description of place and property. The Court found the affidavit and warrant described the building as a garage for business use, identified “cases of whiskey,” and authorized searching rooms connected to the garage by the elevator. The Court held the room where an employee slept was not a private dwelling under the statute and that the agent’s observation, experience, and record check supplied probable cause. The Court therefore upheld the warrant and the seizure.

Real world impact

The ruling means law enforcement can obtain and execute warrants to search business parts of mixed-use buildings and seize contraband when the description and probable cause are adequate. Owners cannot shield business areas by pointing to a small residential room in the same building. The District Court’s refusal to return the liquor was affirmed.