United States v. Steagald, 451 U.S. 204 (1981)

In early 1978, an anonymous informant contacted an agent of the Drug Enforcement Administration (DEA) and indicated he might help the agency locate Ricky Lyons, a fugitive wanted on drug charges. The informant provided a telephone number in Atlanta, Georgia, where Lyons could be reached during the next day. The DEA contacted agent Kelly Goodowens and relayed the information. Goodowens contacted the phone company and obtained an address for the telephone number. Goodowens also learned that Lyons had a six-month-old arrest warrant.
Within a short amount of time, Goodowens and 11 other officers drove to the address. When they arrived, the agents noticed two men standing outside the home. The officers drew their guns, frisked the two men, and determined that neither was Lyons. The men were identified as Hoyt Gaultney and the petitioner, Gary Steagald. When the agents approached the home, Gaultney’s wife answered the door. The agents placed her in a guarded position and searched the house. During the search, an agent discovered what he allegedly believed to be cocaine. Goodo-wens sent an officer to obtain a search warrant and proceeded with a second search of the house. Pursuant to the search warrant, a third search occurred, and the officers discovered 43 pounds of cocaine. Steagald was arrested and indicted on federal drug charges. At the suppression hearing, Goodowens testified he believed the arrest warrant for Lyons justified the entry and search, and that nothing prevented him from obtaining a search warrant.
The Supreme Court has consistently held that entry to a home to search or make an arrest is unconstitutional unless done pursuant to a warrant, or in the existence of consent or exigent circumstances. Thus, the question before the Court in this case was whether an arrest warrant is adequate to protect the Fourth Amendment rights of those not named in the warrant when their homes are searched without consent and there are no exigent circumstances.
In this case, the warrant issued authorized the agents to seize Lyons. However, the Court viewed the agents’ actions as overstepping the legal parameters established in the warrant. The Court determined that the arrest warrant protected only Lyon’s interest in being free from an unreasonable seizure, but not Steagald’s interest in being free from an unreasonable search of his home. Therefore, the Court viewed the search of Steagald’s home as no more reasonable than if it had been conducted in the absence of a warrant.
The Court felt that a contrary conclusion would give police with an arrest warrant the freedom to search an individual’s home, and the homes of that individual’s friends and acquaintances. Therefore, since the agents did not possess a search warrant upon first entry and only an arrest warrant for Lyons, and because no exigent circumstances existed to justify the infringement of Steagald’s Fourth Amendment rights to be secure in his home, the Court ruled that the search of the home was unconstitutional.
The dissent by Justice Rehnquist and Justice White stated that incidental infringements of Fourth Amendment rights might be reasonable in the course of executing a valid warrant. To support this reasoning, the dissent pointed out that requiring a search warrant for each house, given the inherent mobility of a fugitive, would impede the interest of the government and the public in the apprehension of fugitives. The dissenters noted that in Dalia v. United States (1979), the Court rejected the argument that a separate search warrant was required before police could enter a business office to install an eavesdropping device when a warrant authorizing the eavesdropping itself had already been obtained. The Court stated in Dalia that when executing a warrant, police often find it necessary to infringe on other privacy issues or rights not explicitly covered or considered by the judge issuing the warrant. The same situation was applicable in Steagald, according to the dissent. Although the arrest warrant was issued for Lyons, Steagald’s privacy interest was incidental to the execution of a valid arrest warrant, and therefore under a reasonableness standard, the government’s interest in the warrantless entry of a third-party dwelling to execute an arrest warrant was compelling. Moreover, an arrest warrant is limited in its scope of applicability to a third person’s home. It ensures that person that the police are there on official business, and that they may search for the limited purpose of arresting the subject of the warrant. The contraband discovered by the search for Lyons was incidental to the arrest warrant, and not the product of a search warrant.