Steagald v. United States
Headline: Police may not enter someone else’s home to search for a person named in an arrest warrant without a search warrant, except for consent or emergency, protecting residents’ home privacy.
Holding: The Court held that an arrest warrant alone does not allow police to search a third party’s home for the suspect; absent consent or exigent circumstances, officers must obtain a search warrant before entering.
- Requires search warrants before entering a third party's home to look for a suspect (absent emergency or consent).
- Evidence from warrantless third‑party searches may be excluded at trial.
- Police agencies likely must change arrest‑entry procedures and seek warrants more often.
Summary
Background
A Drug Enforcement Administration agent got a tip that a fugitive, Ricky Lyons, could be reached at a phone number. Atlanta agents traced the number to an address and went to that house. They found Gary Steagald outside, frisked him, and then entered the home without a search warrant. During the entry an agent saw suspected cocaine, they later obtained a search warrant, and a full search recovered 43 pounds of cocaine. Steagald was arrested and challenged the searches.
Reasoning
The Court framed the narrow question as whether an arrest warrant for one person allows police to search a third person’s home without a search warrant. The majority held it does not. An arrest warrant authorizes seizure of the named suspect but does not substitute for a judicial finding that evidence or the suspect is inside someone else’s house. Absent consent or an emergency, a magistrate must review probable cause to search the particular home.
Real world impact
The decision requires officers to get a search warrant before entering a third party’s home to look for a suspect unless an emergency or consent applies. That makes it more likely evidence from warrantless third‑party entries will be suppressed and pushes police to change entry procedures. The ruling affirmed that neutral judicial review protects residents’ privacy in their homes.
Dissents or concurrances
Justice Rehnquist (joined by Justice White) dissented, arguing the ruling hampers law enforcement because fugitives are mobile and common law supported entry to arrest suspects; the Chief Justice concurred in the judgment.
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