Steagald v. United States Essay Example

  • Category:
    Law
  • Document type:
    Case Study
  • Level:
    Undergraduate
  • Page:
    3
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    1609

STEAGALD V UNITED STATES 2

Steagald v United States

Introduction

In Steagald v United States, Drug Enforcement Agency personnel had entered the house of the defendant, as they had information that the fugitive Lyons was hiding in that place. After effecting an armed entry, these agents confiscated 43 lbs. of cocaine from the defendant’s house and charged him for the same. The US Supreme Court ruled that an arrest warrant was insufficient for entering the residence of a third party. Such entry had to be supported by a search warrant. The arrest warrant did not safeguard the defendant’s interest in freedom from unreasonable searches of his house[ CITATION Ste81 l 16393 ]. As such, the US Supreme Court had emphasized, in Steagald v United States that the necessity for police to carry out warrantless searches was subordinate to the right of the people to be secure in their houses against unreasonable searches and confiscations[CITATION Wat81 p 1263 l 1033 ].

It is important in the sense that free societies are characterized by freedom from unreasonable searches. The Fourth Amendment supports the principle that the home of a person is protected from random invasions by the government. The privacy of the home of individuals is guaranteed by the law, by requiring law enforcement to procure a search warrant for intruding into a person’s home [CITATION Wen82 p 652 l 1033 ]. Such warrant has to be issued by a neutral and unbiased magistrate, for the purpose of determination of probable cause.

In Steagald v United States, the dwelling of Steagald had been entered by federal agents. Their objective had been to search for a fugitive, and they had an arrest warrant and reasonable belief that the suspect was to be found on the premises. The federal agents failed to find the fugitive. However, they saw drugs in the premises. Subsequently, the defendant had been arrested and convicted on federal drug charges. The defendant had asserted at the district court, during the trial that entry of the federal agents, in the absence of a search warrant had infringed his rights under the Fourth Amendment to the US Constitution[CITATION Wen82 p 652 l 1033 ].

In this case, the Drug Enforcement Administration agents had obtained information that Lyons, a fugitive, was hiding in the residence of the defendant. These agents obtained an arrest warrant for Lyons, and solely on the basis of this warrant, they entered and examined the defendant’s house. During that search, they discovered drugs and this culminated in criminal charges being made against the defendant, Steagald.

Procedural History

In this case, the district court held the defendant guilty and convicted him, after dismissing his motion to suppress the evidence. This decision was upheld by the Fifth Circuit. However, the US Supreme Court granted certiorari and held that in the absence of consent or exigent circumstances, law officers were required under the Fourth Amendment to procure a search warrant prior to subjecting the dwelling of a third party to a search[CITATION Pat82 p 1410 l 1033 ].

As such, the district court had denied the pretrial motion of the defendant to suppress the drugs, as illegally obtained evidence. At the Fifth Circuit Court of Appeals, a divided bench upheld the conviction of the defendant. Finally, the United States Supreme Court, on certiorari held, reversed and remanded. Thus, an arrest warrant fails to provide sufficient protection towards the Fourth Amendment interests of third parties who had not been included in the arrest warrant, when their residence had been subjected to a search for a suspect without their consent or in the absence of exigent circumstances[CITATION Wen82 p 652 l 1033 ].

Whether the search of a third-party home without search warrant, while arresting the offender, violates the Fourth Amendment privacy rights.

The issue of this case was whether police officers had to procure a search warrant for searching the house of a third party, in the absence of consent or exigent circumstances.

In this case, the US Supreme Court held that in the absence of consent or exigent circumstances, police officers were obliged to obtain a search warrant before searching the dwelling of a third party[CITATION Pat82 p 1409 l 1033 ].

It had been contended by the respondent, in this case that an arrest warrant was sufficient for entering and searching the dwelling of the petitioner. However, the US Supreme Court held that a search warrant was essential for entering and searching a house for the subject of an arrest, unless there had been consent or exigent circumstances[CITATION Hun82 p 159 l 1033 ]. The right of privacy in a person’s home, in comparison to the interests of the government in enforcing the law, had been analyzed in this case.

Rationale

In Steagald v United States, the US Supreme Court applied sound reasoning. It held that an analysis of the Fourth Amendment made it evident that it was unreasonable to search the premises of a person without a search warrant, until and unless it was one of the carefully defined exceptions. The search carried out by the agents of the Drug Enforcement Agency was not one of the exceptions to the requirement for a search warrant[CITATION Wat81 p 1269 l 1033 ].Thus, as per the majority decision, a search warrant had been essential for making the search reasonable.

The US Supreme Court rescinded the ruling of the lower courts by a 7-2 vote. Marshall J, provided the majority ruling, which held that a search warrant was essential for safeguarding third party privacy interests, at the time of entry into their homes by the police, in search of a suspect against whom they had obtained an arrest warrant. The dissenting opinion was provided by Rehnquist J and White J[CITATION Wat81 p 1266 l 1033 ]. However, the Court did not fully explain why the Fourth Amendment rights of the people were superior to the need to conduct a warrantless search. In his dissent, Rehnquist J, carried out a balancing test and came to the conclusion that protection of the privacy of a home was subservient to the need to carry out a warrantless search[CITATION Wat81 p 1264 l 1033 ].

Significance

Prior to the decision in Steagald v United States, the courts had not provided a clear decision regarding the issues arising from warrantless entry for effecting felony arrests, whenever police officers had entered the house of a third party for that purpose. In general, it is essential for law enforcement officers to possess a valid search warrant, prior to entering the house of a third party for making an arrest. However, if the householder consents to the conduct of the search, then law enforcement officers can enter the house and effect an arrest or make a search without a search warrant[ CITATION Can81 l 1033 ]. In the absence of a search warrant, the presence of exigent circumstances and probable cause are indispensable for entering a house to make an arrest.

Nevertheless, the intention of the Fourth Amendment is not to safeguard criminals or to make the home a safe haven for criminal activities. Its purpose is to highlight the importance of individual privacy rights, and to curb law enforcement from violating these rights unreasonably. For instance, the US Supreme Court’s ruling in Minnesota v Carter, served to strike the appropriate balance between individual privacy rights, and detection of crime and arrest of criminals.

In Minnesota v Carter, a police officer had peered through a window in a lessee’s apartment. He noticed that the respondents, in a third party’s apartment, were packing cocaine. Thereupon, the police officer procured a warrant on the basis of that observation. The respondents made a motion to suppress the evidence, claiming that their Fourth Amendment rights had been violated by the act of observation by the officer. The trial court held that the offenders were not entitled to Fourth Amendment protection and that the officer’s observation was not a search under the said amendment. The Court of Appeals ruled that the respondents were not entitled to object to the actions of the officer, as the apartment had been used by them for the illegal activity of packaging cocaine. The State Supreme Court reversed this judgment and held that the respondents had standing to claim Fourth Amendment protection[CITATION Min98 l 1033 ]. Finally, the US Supreme Court rescinded the State Supreme Court decision and ruled the respondents had no legitimate expectation of privacy in a third party’s apartment.

List of References

Cannaday, K. S. (1981). Routine Felony Arrest May Not Be Made in the Home of a Third Party Without a Search Warrant — Supreme Court Announces Rule in Steagald v United States. Retrieved November 27, 2016, from National Criminal Justice Reference Service: https://www.ncjrs.gov/App/Publications/abstract.aspx?ID=97587

Hunt, G. R. (1982). Case Development: Criminal Procedure — Search and Seizure — Warrantless Search of Third Party’s Home for Subject of an Arrest Warrant is Violative of the Fourth Amendment: Steagald v. United States. Howard Law Journal, 25, 159.

Minnesota v Carter, 525 US 83 (Supreme Court of the United States December 1, 1998).

Patterson, B. A. (1982). Search Warrant Required to Search Third Party Home for Subject of Arrest Warrant, Steagald v. United States, 101 S. Ct. 1642 (1981). Washington University Law Review, 59(4), 1409-1424.

Steagald v United States , 451 US 204 (Supreme Court of the United States April 21, 1981).

Watson, G. A. (1981). Fourth Amendment—Balancing the Interests in Third Party Home Arrests. Journal of Criminal Law and Criminology, 72(4), 1263-1275.

Wenige, L. O. (1982). Criminal Law and Procedure—Searches of Third Party Homes—Adequacy of Arrest Warrant to Protect Third Party’s Privacy Rights. Tennessee Law Review, 49, 652