Steagald v. United States (1981) Case Brief Essay Example

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Running header: Steagald v. United States (1981) Case Brief

Steagald v. United States (1981) Case Brief

City and State Where Institution is Located

Steagald v. United States (1981) Case Brief


This case is about the application of the fourth amendment regarding whether it prevents police officers from searching for a suspect in the home of a third party without first obtaining a search warrant. In other words, the case sought to establish whether an arrest warrant as opposed to a search warrant is adequate to protect the fourth amendment interests of third parties or persons not named in the warrant if or when their homes are searched without their consent and where there are no exigent circumstances. This case is important as its determination or its result would shed light on the protection of third party fourth amendment interests’ protection. In other words, its determination guides law enforcers on whether they can just enter a third party’s homes and search them although there has not been consent or warrant1.Are law enforcers for instance at liberty to search a suspect’s relatives or friend’s homes without consent? As such, this case is important as its determination would determine the extent to which law enforcers can go in obtaining evidence as well as the extent to which the rights of third parties extend in such a process.

Facts of the case

On 4th January 1978, a Drug Enforcement Administration (DEA) agent got information from a confidential informant that he might be able to locate Ricky Lyons who was a federal fugitive wanted on drug charges. The informant later gave the DEA agent a telephone number in the Atlanta area where the informant claimed that Ricky Lyons could be reached in the next 24 hours. The DEA agent on January 16th 1978 relayed this information to a fellow DEA agent in Atlanta Kelly Goodowens. Goodowens secured the address corresponding to the telephone number obtained from the informant from Southern Bell Telephone Co and also discovered that Lyons had been the subject of a six month old arrest warrant. Two days later, Goodowens and other officers went to the address obtained from the phone company to search for Lyons. It is worth noting that the address belonged to Steagald. As such, pursuant to the arrest warrant for Lyons, the DEA agents entered Steagald’s home without first obtaining a search warrant. In the course of the search, the DEA agents found cocaine and other incriminating evidence although they did not find Lyons. When the lead agent was informed of the initial observation of cocaine in Steagald’s home, he sent an officer for search warrant. The officers while waiting for the warrant conducted a second search that revealed more incriminating evidence. When the officer brought the warrant, a third search was conducted which revealed 43 pounds of cocaine. They arrested Steagald and preferred federal drug charges against him. However, Steagald moved to suppress all the evidence on the basis that the officers had failed to obtain a search warrant for the house before conducting the search2. However at the trial level, this argument was denied by the district court and hence Steagald was convicted. This resulted in the case going to the appeal court. However at the appellate level, the trial court decision was overturned owing to the fact that the fourth amendment prevents all warrantless searches of homes unless there are clear exigent circumstances. Though the agents had an arrest warrant against Lyons, it did not extend to search Steagald’s home. However, 2 out of the 9 judges dissented from the appellate court decision.

The issue before the court was whether an arrest warrant as opposed to a search warrant is adequate to protect the 4th amendment interests of persons not named in the warrant, if or when their homes are searched without their consent and where there are no exigent circumstances.

The court decided that an arrest warrant as opposed to a search warrant is not adequate to protect the 4th amendment interests of person’s not named in the warrant, when their homes are searched without their consent and in the absence of exigent circumstances.


The reason behind the court’s decision is that the entry to a home to search or make an arrest is unconstitutional unless it is done pursuant to a warrant or in the existence of consent or where exigent circumstances exist. The court viewed the actions by the agents as having overstepped the legal parameters established in the warrant of arrest. It was determined that the arrest warrant only protected Lyon’s interest in being free from unreasonable seizure but not Steagald’s interest in being free from an unreasonable search of his home. As such, the appellate court was of the view that the search of Steagald’s home as no more reasonable than if the search had been conducted in the absence of a warrant3. The court was of the opinion that if a contrary conclusion was arrived at, it would give the police with an arrest warrant the freedom to search an individual’s home as well as the homes of the suspect’s friends and acquaintances. As such, given that the agents did not have a search warrant upon their first entry and only had an arrest warrant for Lyons and since there were no exigent circumstances justifying the infringement of Steagald’s fourth amendment rights of being secure in his home, then the search of his home was deemed unconstitutional.

In making the decision, there was a dissent by two judges and a concurring opinion by the rest of the judges. Seven judges out of the nine judges voted with the majority. Justice Thurgood Marshall gave the opinion by the 7-2 majority while Chief Justice Warren E. Burger gave a concurring opinion. On the other hand, Justice William H. Rehnquist gave the dissenting opinion4. The reason behind the dissent was that were the police to have had a valid search warrant and believing that Lyon was in the house, they would have been able to carry on the search reasonably to carry out the warrant of arrest. Thus, the arrest warrant could serve as a search warrant since it serves to limit the scope of the search. Furthermore, the state has a compelling interest in the search owing to the inherent mobility of the suspect. Another dissenting judge was Justice Byron R. White.


The decision by the appellate court in this case has greatly changed the work of law enforcement and the criminal justice system as well. The agents in this case had used an arrest warrant as an excuse to search the house of a third party for two times before securing a search warrant despite absence of exigent circumstances. Consequently, their effort was rendered fruitless by the decision in that they should have secured a search warrant before conducting the search. Law enforcers can now not search a third party’s house without securing a search warrant. Furthermore, they cannot use an arrest or search warrant to arrest or search a third party. This is a win for criminal justice system since third parties such as relatives and friends of suspects or convicts are now assured of their fourth amendment rights. As such, the decision has gone a long way into further laying bare what the law enforcers can or cannot do as far as searching of third parties premises is concerned. It is important for us to study the specifics of this case since at times in the course of law enforcement, many officers make a lot of assumptions. For instance, there are many instances where many people including I have been subjected to searches that at times can even be described as harassment by law enforcers just because we had been seen with a suspect or just because a suspect is a friend or a relative. Thus, studying this case in detail is important so as to realize our rights while making us better law enforcers in future.

References, 2016, Steagald v. United States 451 U.S. 204 (1981), Retrieved on 18th November 2016, from;, 2016, Summary of Steagald v. United States, United States Supreme Court, 1981, Retrieved on 18th November 2016, from;, 2016, Search and Seizure Case Briefs, Retrieved on 18th November 2016, from,, 2016, Steagald v. United States, Retrieved on 18th November 2016, from;

1, 2016.

2, 2016.

3, 2016

4, 2016