Steagald v. United States
Decided on Apr. 21, 1981; 451 US 204


Man arrested when his house is raided by DEA agents searching for someone else

I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed: Criminal Justice (drugs), 4th Amendment

B. Legal Question Presented:

Is an arrest warrant – as opposed to a search warrant –  adequate to protect the Fourth Amendment interests of persons not named in the warrant, when their homes are searched without their consent and in the absence of exigent circumstances?  

II. CASE SUMMARY:

A. Background:

Petitioner, Steagald, was arrested after a search of his home by Drug Enforcement Administration agents. Originally pursuant to an arrest warrant for Ricky Lyons, the agents entered petitioner's home in search of Lyons. In the course of searching the home, agents did not find their subject, but they found cocaine and other incriminating evidence against petitioner. Steagald was subsequently arrested and indicted on federal drug charges.

Prior to his trial, petitioner moved to suppress all evidence uncovered during the search of his home on the ground that it was illegally confiscated because the agents had failed to obtain a search warrant. The motion was denied by the District Court, and petitioner was convicted of the federal drug charges. The Court of Appeals affirmed the lower court's ruling and held that petitioner’s Fourth Amendment right was not violated.  Steagald sought review of the judgment by the US Supreme Court and the high court granted certirorari to review the case.
B. Counsel of Record:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
John Richard Young, by appointment of the court, argued the cause and filed a brief for petitioner.
Deputy Solicitor General Frey argued the cause for the United States. With him on the brief were Solicitor General McCree, Assistant Attorney General Heymann, Peter Buscemi, Elliott Schulder, William G. Otis, and Patty Merkamp Stemler.
C. The Arguments:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
"The federal agents in this case insist upon a distinction, for Fourth Amendment purposes, between searching for things and searching for persons in a house, arguing that in the latter category of cases, when in possession of an arrest warrant, they need not obtain a search warrant describing the premises to be entered in search of their suspect. This distinction makes no sense, however, for two reasons. First, the invasion of the privacy of a citizen's home is unaffected by the object of the policeman's search. Second, the Fourth Amendment preference for judicial rather than police determinations of probable cause for searches is no less forceful because the intended search is for persons rather than things. The Fourth Amendment requires that, absent exigent circumstances, a search of particular premises must be based upon the determination of a judge or magistrate that there is probable cause to believe that the object of the search - whether 'person' or 'thing' - is within the premises to be entered. Only in the course of such a determination can the privacy of citizens in their homes be appropriately weighed against the interest of the government in seizing evidence or apprehending suspects." – ACLU brief in Steagald v. United States Unavailable


 

III. AMICI CURIAE:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
John McNally filed a brief for the American Civil Liberties Union et al. as amici curiae urging reversal. No brief filed as amicus curiae on behalf of Respondent.
IV. THE SUPREME COURT'S DECISION:

"Whether the arrest warrant issued in this case adequately safeguarded the interests protected by the Fourth Amendment depends upon what the warrant authorized the agents to do... [T]he agents… relied on the warrant as legal authority to enter the home of a third person based on their belief that Ricky Lyons might be a guest there… Thus, while the warrant in this case may have protected Lyons from an unreasonable seizure, it did absolutely nothing to protect petitioner's privacy interest in being free from an unreasonable invasion and search of his home... In the absence of exigent circumstances, we have consistently held that such judicially untested determinations are not reliable enough to justify an entry into a person's home to arrest him without a warrant, or a search of a home for objects in the absence of a search warrant...

[T]wo distinct interests were implicated by the search at issue here - Ricky Lyons' interest in being free from an unreasonable seizure and petitioner's interest in being free from an unreasonable search of his home. Because the arrest warrant for Lyons addressed only the former interest, the search of petitioner's home was no more reasonable from petitioner's perspective than it would have been if conducted in the absence of any warrant. Since warrantless searches of a home are impermissible absent consent or exigent circumstances, we conclude that the instant search violated the Fourth Amendment…

An arrest warrant, to the extent that it is invoked as authority to enter the homes of third parties, suffers from the same infirmity. Like a writ of assistance, it specifies only the object of a search - in this case, Ricky Lyons - and leaves to the unfettered discretion of the police the decision as to which particular homes should be searched. We do not believe that the Framers of the Fourth Amendment would have condoned such a result... Any warrant requirement impedes to some extent the vigor with which the Government can seek to enforce its laws, yet the Fourth Amendment recognizes that this restraint is necessary in some cases to protect against unreasonable searches and seizures. We conclude that this is such a case. The additional burden imposed on the police by a warrant requirement is minimal. In contrast, the right protected - that of presumptively innocent people to be secure in their homes from unjustified, forcible intrusions by the Government - is weighty. Thus, in order to render the instant search reasonable under the Fourth Amendment, a search warrant was required.

Accordingly, the judgment of the Court of Appeals is reversed, and the case is remanded to that court for further proceedings consistent with this opinion."
Justice Vote: 7 Pro vs. 2 Con

  • Marshall, T. Pro (Wrote majority opinion)
  • Stevens, J. Pro (Joined majority opinion)
  • Brennan, W. Pro (Joined majority opinion)
  • Stewart, P. Pro (Joined majority opinion)
  • Blackmun, H. Pro (Joined majority opinion)
  • Powell, L. Pro (Joined majority opinion)
  • Burger, W. Pro (Wrote concurring opinion)
  • Rehnquist, W. Con (Wrote dissenting opinion)
  • White B. Con (Joined dissenting opinion)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU filed as amicus urging reversal; the US Supreme Court reversed and remanded the ruling of the United States Court of Appeals for the Fifth Circuit in a 7-2 vote, giving the ACLU an apparent win.