Summary of Steagald v. United States, United States Supreme Court, 1981

Statement of the Case:

Steagald, raided cocaine owner, was arrested and indicted on federal drug charges when his house was raided looking for someone else, but drugs, not the felon, were found.

Procedure:

Trial court convicted Steagald.

Facts:

  DEA got a tip from an informant that a federal fugitive, Lyons, could be reached at a phone number for the next 24 hours.  The number correlated to a house in GA.  2 days later, federal agents reached the house of Gary Steagald.  Officers apprehended him and his friend, then, realizing neither was the wanted man, raided Steagald’s house, and found cocaine instead.  They then got a warrant for the house and found 43 pounds of cocaine.

Issue:

Whether an arrest warrant, as opposed to a search warrant, is adequate to protect the 4^th amendment interests of persons not named in the warrant, when their homes are searched without their consent and in the absence of exigent circumstances.

Procedural Result:

Judgment reversed on 4^th amendment grounds.

Holding:

An arrest warrant, as opposed to a search warrant, is NOT adequate to protect the 4^th amendment interests of persons not named in the warrant, when their homes are searched without their consent and in the absence of exigent circumstances.

Reasoning:

• Agents used an arrest warrant for a 3^rd person in order to enter someone else’s house.
• If this logic held, the police could get a search warrant for one person, and search everyone’s houses all over, without their consent.

Dissent:

• If a suspect had even been at a home for a few days, it would be enough to be considered a home.
• It also makes clear that if it were the person they were looking for lived at that home, it would be acceptable to search it with an arrest warrant.

Additional Points:

United States v. Santana:  Court held suspected felon who stood precisely in the threshold of her front door was subject to warrantless arrest under the Watson holding.  She was in a “public place” for 4^th amendment purposes – the equivalent of her standing completely outside her house.