Master The Supreme Court held that, absent consent or exigent circumstances, officers must obtain a search warrant to enter a third party's home to look for the subject of an arrest warrant. with this comprehensive case brief.
Steagald v. United States is a cornerstone Fourth Amendment case that draws a bright doctrinal line between arrest warrants and search warrants. It clarifies that an arrest warrant authorizes police to seize a person, but it does not, by itself, authorize entry into a third party's home to look for that person. To cross a homeowner's threshold, officers generally need a search warrant supported by probable cause that the person sought is inside that particular dwelling, unless a recognized exception (such as consent or exigency) applies.
Coming shortly after Payton v. New York, which held that an arrest warrant permits entry into the suspect's own home when there is reason to believe the suspect is present, Steagald confirms that the privacy interests of third parties are distinct and independently protected. For law students, the case is a critical study in warrant particularity, the allocation of privacy interests between suspects and homeowners, and the practical implications for suppression motions when officers conflate the roles of arrest and search warrants.
Steagald v. United States, 451 U.S. 204 (1981)
Federal agents obtained an arrest warrant for a fugitive, Lyons, based on drug charges. Acting on a confidential informant's tip that Lyons would be at the residence of Gary Steagald in Georgia for a short time, DEA agents went to Steagald's home without a search warrant. They entered the house without consent and conducted a sweep to locate Lyons. Lyons was not found, but during the search agents observed cocaine. The agents then secured the residence, obtained a search warrant relying in part on what they had just seen, and returned to seize the drugs. Steagald was charged with federal drug offenses. He moved to suppress the evidence, arguing that the initial entry and search violated the Fourth Amendment because the officers had only an arrest warrant for Lyons and no search warrant for Steagald's home. The district court denied suppression and the court of appeals affirmed, reasoning that the arrest warrant justified the entry. The Supreme Court granted certiorari.
Does an arrest warrant authorize police to enter and search the home of a third party to look for the subject of the arrest warrant, or must officers obtain a search warrant (absent consent or exigent circumstances) to enter that third party's residence?
Under the Fourth Amendment, an arrest warrant authorizes the seizure of the named person, including entry into the suspect's own residence when there is reason to believe the suspect is inside. However, absent consent or exigent circumstances, officers must obtain a search warrant, supported by probable cause that the person sought is within, to enter and search the home of a third party for the subject of an arrest warrant. The search warrant requirement protects the distinctive privacy interests of the homeowner or lawful occupant.
No. An arrest warrant does not, by itself, authorize the entry and search of a third party's home to look for the person named in the warrant. Without consent or exigent circumstances, officers must obtain a search warrant for that residence. Because the entry into Steagald's home was based only on an arrest warrant for Lyons, the search violated the Fourth Amendment and the evidence should have been suppressed.
The Court emphasized that arrest and search warrants serve different constitutional interests. An arrest warrant is based on probable cause that a specific individual committed a crime and protects that individual's interest in not being seized unreasonably; it does not address the separate privacy interest of a homeowner whose premises are searched. In contrast, a search warrant is issued upon a neutral magistrate's determination of probable cause to believe that a specific place contains the person or items sought, and it limits the scope of intrusion by describing the place to be searched. Relying on Payton v. New York, the Court recognized that officers with an arrest warrant may enter the suspect's own home if they reasonably believe the suspect is inside. But Payton does not extend to the home of a third party. Allowing officers to enter any residence they subjectively believe might contain the arrestee, without a magistrate's ex ante review, would invite widespread intrusions on the privacy of people not suspected of wrongdoing and would circumvent the particularity and probable cause safeguards embedded in the warrant process. The warrant requirement ensures a neutral evaluation of whether there is probable cause to think the person sought is in the specific dwelling to be entered. The government also argued that Steagald lacked standing to object because the arrest warrant targeted Lyons. The Court rejected this argument, explaining that Fourth Amendment rights are personal and that Steagald plainly had a reasonable expectation of privacy in his own home; the violation was of his privacy, not of Lyons's. Finally, the Court found no applicable exception: officers had time to obtain a search warrant based on the informant's tip but elected not to do so, there was no exigency, and there was no valid consent. Because the later search warrant was obtained using information observed during the unlawful entry, suppression was required absent an independent source.
Steagald is a foundational case delineating the scope of arrest versus search warrants and the distinct Fourth Amendment interests they protect. It teaches that: (1) an arrest warrant cannot be used as a proxy for a search warrant when officers want to enter a third party's home; (2) homeowners have their own enforceable privacy interests, even when they are not the targets of law enforcement; and (3) magistrate review is essential to tie probable cause to the specific place to be searched. For law students, Steagald is frequently tested alongside Payton to assess mastery of when officers need an arrest warrant, a search warrant, both, or neither, and how consent and exigency alter the analysis.
Payton permits officers with an arrest warrant to enter the suspect's own home when they have reason to believe the suspect is inside. Steagald limits that rule by holding that an arrest warrant alone does not authorize entry into a third party's home. For a third party's residence, officers need a search warrant (or consent or exigent circumstances) because the homeowner's privacy interests are distinct from the arrestee's.
If the residence is in fact the suspect's dwelling and officers have an arrest warrant and reason to believe the suspect is present, Payton allows entry. But where the residence belongs to a third party, Steagald requires a search warrant. The key is whether officers have probable cause to treat the location as the suspect's home and to believe the suspect is then inside; absent that, entry into a third party's home requires a search warrant or a valid exception.
Yes. Steagald recognizes standard exceptions. Officers may enter without a search warrant if exigent circumstances exist, such as hot pursuit, imminent destruction of evidence, or immediate threats to safety. Valid consent from someone with actual or apparent authority over the premises also obviates the need for a warrant, though the scope of consent limits the permissible search.
Plain view requires a lawful initial intrusion. If entry into a third party's home is unlawful under Steagald because there was no search warrant, consent, or exigency, the plain-view doctrine does not validate observations or seizures. A later warrant based on tainted observations is ordinarily invalid unless the government can show an independent source or inevitable discovery.
The person whose home was entered does. Fourth Amendment rights are personal. Even though the arrest warrant concerns the arrestee, the homeowner or lawful occupant has a reasonable expectation of privacy in the premises and may seek suppression of evidence obtained through an unlawful entry and search of that home.
Steagald v. United States reaffirms that Fourth Amendment protections hinge not only on who is suspected, but also on where the intrusion occurs. An arrest warrant targets a person; a search warrant targets a place. When officers cross into a third party's home to look for a suspect, a search warrant—reflecting a magistrate's judgment that the person is likely inside—is the constitutional default.
For practitioners and students, Steagald is a caution against collapsing distinct warrant requirements and a guidepost for analyzing suppression issues. It underscores the need to match the warrant to the privacy interest at stake and to assess carefully whether any exception legitimately substitutes for the neutral magistrate's prior review.