Steagald v. United States, 451 U.S. 204 (1981) (U.S. Supreme Court)
Steagald v. United States is a cornerstone Fourth Amendment case that draws a bright line between the authority conferred by an arrest warrant and the privacy protections secured by a search warrant.
Does a valid arrest warrant for a suspect authorize law enforcement officers to enter and search the home of a third party to look for the suspect, absent consent or exigent circumstances, without a search warrant for that home?
Absent consent or exigent circumstances, the Fourth Amendment requires officers to obtain a search warrant—supported by probable cause to believe the person sought is on the premises and particularly describing the place to be searched—before entering and searching the home of a third party to execute an arrest warrant. While an arrest warrant may authorize entry into the suspect's own home when there is reason to believe the suspect is within (Payton v. New York), it does not extend to the home of another, whose distinct privacy interests are protected by the search warrant requirement.
No. An arrest warrant for a suspect does not authorize the entry into and search of a third party's residence to look for that suspect. A search warrant is required unless there is valid consent or exigent circumstances. The evidence found in Steagald's home as a result of the unlawful entry must be suppressed.
Steagald is a bedrock Fourth Amendment decision that every law student should know. It crisply delineates the distinct functions of arrest and search warrants, tying each to the specific privacy interests they protect. The case is frequently used to test understanding of whose rights are implicated by a search, how Payton's rule applies, and when exceptions like consent or exigency can substitute for a warrant. Practically, Steagald directs law enforcement to obtain a search warrant before entering a third party's home to execute an arrest warrant—thereby preventing broad, suspicion-based sweeps of private residences without judicial oversight.