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Law School Case Brief

Steagald v. United States - 451 U.S. 204, 101 S. Ct. 1642 (1981)


Under the Fourth Amendment, a search warrant must be obtained, absent exigent circumstances or consent, for a law enforcement officer to legally search for the subject of an arrest warrant in the home of a third party. 


Pursuant to an arrest warrant for a person named Lyons, federal Drug Enforcement Administration agents entered the home of petitioner Gary Keith Steagald home to search for Lyons; the agents did not first obtaining a search warrant before entering the home. In the course of searching the home, the agents found cocaine and other incriminating evidence; they did not find Lyons. Steagald was then arrested and indicted on federal drug charges. At trial in federal district court, Steagald's pretrial motion to suppress all evidence uncovered during the search of his home on the ground that it was illegally obtained because the agents had failed to obtain a search warrant was denied. Steagald was convicted. On appeal, the court of appeals affirmed the district court's denial of the Steagald's motion to suppress.


Was it error to deny Steagald's motion to suppress?




The Supreme Court of the United States reversed the judgment that affirmed the denial of Steagald's motion to suppress. The Court ruled that Steagald's rights were violated when the agents, in the absence of consent and exigent circumstances, entered his home and searched for the subject of an arrest warrant without first obtaining a search warrant. The Court held that the agents could not, consistent with the Fourth Amendment, search for the subject of the arrest warrant in the Steagald's home without first obtaining a search warrant, absent consent or exigent circumstances, since: (1) the requirement of a search warrant would not significantly impede effective law enforcement efforts when weighed against the constitutional issues at stake; (2) Steagald had a Fourth Amendment privacy interest in being free from unreasonable invasion and search of his home, and; (3) the arrest warrant served to protect only the person named in the warrant from an unreasonable seizure, but did nothing to protect Steagald's interest in the privacy of his home against the unjustified intrusion of federal agents.

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