Steagald v. United States

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Steagald v. United States
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued January 14, 1981
Decided April 21, 1981
Full case nameGary Steagald v. United States
Citations451 U.S. 204 ( more )
101 S. Ct. 1642; 68 L. Ed. 2d 38
Case history
Prior606 F.2d 540, 615 F.2d 642 (affirming district court's denial of motion to suppress and upholding convictions)
Holding
An arrest warrant is not sufficient under the Fourth Amendment to search the home of a third party unless exigent circumstances are present.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr.  · Potter Stewart
Byron White  · Thurgood Marshall
Harry Blackmun  · Lewis F. Powell Jr.
William Rehnquist  · John P. Stevens
Case opinions
MajorityMarshall, joined by Brennan, Stewart, Blackmun, Powell, Stevens
ConcurrenceBurger
DissentRehnquist, joined by White
Laws applied
U.S. Const. amend. IV
21 U.S.C. §§ 841(a)(1), 846

Steagald v. United States, 451 U.S. 204 (1981), is a United States Supreme Court case which held that, based on the Fourth Amendment, a police officer may not conduct a warrantless search of a third party's home in an attempt to apprehend the subject of an arrest warrant, absent consent or exigent circumstances. [1]

Contents

Factual background

In mid-January 1978, a confidential informant contacted an agent of the Drug Enforcement Administration (DEA) in Detroit and provided an Atlanta-area telephone number at which Ricky Lyons, a fugitive subject to a federal arrest warrant related to a marijuana indictment dating back to July 1977, could be reached for the next 24 hours. [1] [2] The Michigan DEA agent relayed the information to a DEA agent in Atlanta, Kelly Goodowens. [1] After contacting Southern Bell Telephone Company to obtain the address corresponding to the telephone number, Goodowens, along with eleven other police officers and federal agents, drove to the lakeside cottage in Buford in order to apprehend the fugitive. [1] [3]

Upon arrival at the address, the officers encountered Hoyt Gaultney and Gary Keith Steagald working on a vehicle outside the home. [1] [2] After frisking both and determining that neither was Lyons, the officers proceeded to the front door, where they met Gaultney's wife, Cathy, who advised that no one else was present in the home. [1] [4] The police nevertheless instructed Gaultney's wife to place her hands on a wall while they conducted a search of the home for Lyons. [1] Although they did not find Lyons, they discovered a small amount of cocaine. [1] Agent Goodowens then instructed a colleague to obtain a search warrant for the home while he and the rest of the officers conducted a second search of the home, which uncovered more cocaine. [1] Once the search warrant for the home was obtained, the house was searched for a third time revealing a clear plastic bag containing 450 grams (approx. 1 pound) of 45% pure cocaine hydrochloride, two suitcases containing 8,394 grams (approx. 18.5 pounds) of 99% pure cocaine hydrochloride and 10,445 grams (approx 23 pounds) of 95% pure cocaine hydrochloride respectively, a box of clear plastic bags, two sets of Ohaus triple beam balance scales, and a bag containing beta-mannitol, a common cutting agent. [4] The approximately 43 pounds of cocaine, with a wholesale value of some $2.5 million at the time, had been smuggled as custom imports from Colombia in hollowed-out ornamental brass lamps and table bases. [3] [4] Gualtney and Steagald were both indicted on federal drug charges as a result. [1] While the officers were at the home, James "Jimmy" Albert Smith, to whom the house in question had been leased and who was the subject of a state arrest warrant related to drug charges, arrived in a pickup truck and was immediately arrested. [2] [4]

Procedural history

Steagald asked the trial court to suppress the evidence discovered through the warrantless search pursuant to the exclusionary rule. [1] The trial court denied the motion to suppress and Gualtney and Steagald were convicted. [4] Steagald and Gaultney then moved for a mistrial, which the trial court denied, prompting them to appeal the convictions to United States Court of Appeals for the Fifth Circuit. In a 2–1 opinion, the Fifth Circuit agreed with the district court that the arrest warrant for Lyons was sufficient grounds for law enforcement to search the premises and affirmed the convictions. [4] In so doing, the Fifth Circuit relied on their own precedent in United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 1976), which held that "when an officer holds a valid arrest warrant and reasonably believes that its subject is within premises belonging to a third party, he need not obtain a search warrant to enter for the purpose of arresting the subject." [4] Steagald then appealed to the Supreme Court of the United States, which granted certiorari to decide whether the government may search a third-party's property pursuant to an arrest warrant without the owner's consent. [5]

Supreme Court decision

Justice Thurgood Marshall delivered the majority opinion of the court, in which he was joined by all of the remaining justices on the court except for William Rehnquist, in favor of Steagald. [5] The court held that an arrest warrant authorizes police to arrest the subject of the warrant, but does not authorize them to enter a third party's home in search of that person. [5] The court reasoned that since the purpose of a warrant is to allow for judicial review of determinations by law enforcement regarding probable cause, an arrest warrant is distinct from a search warrant in that the probable-cause determination under review is different. [5] An arrest warrant certifies that there is probable cause that a person has committed a crime and therefore the police are justified in seizing (i.e., taking into custody) the subject of the warrant. [5] For a search warrant, on the other hand, the judicial officer reviews whether the police have probable cause to search a particular location for a specific object, justifying intrusion of the interest in privacy by entering the premises. [5] Allowing the police to enter any place where they suspected the subject of an arrest warrant might be would pave the way for abuse because police could, for example, search the home of every known family member and acquaintance of the subject. [5] Accordingly, the Supreme Court reversed the Fifth Circuit's ruling that an arrest warrant justifies the search of a third party's home and remanded the case to the trial court for further proceedings consistent with the Fourth Amendment. [5]

Justice Rehnquist, in his dissent, argued that it is not reasonable to expect the police to secure a separate warrant for premises belonging to a third party when they already have probable cause to believe the fugitive is there because fugitives are, by their very nature, highly mobile. [5] Therefore, while the police are attempting to secure the warrant, the suspect might escape. [5]

See also

Related Research Articles

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A search warrant is a court order that a magistrate or judge issues to authorize law enforcement officers to conduct a search of a person, location, or vehicle for evidence of a crime and to confiscate any evidence they find. In most countries, a search warrant cannot be issued in aid of civil process.


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In criminal procedure law of the United States, an exigent circumstance allows law enforcement to enter a structure without a search warrant, or if they have a "knock and announce" warrant, allows them to enter without knocking and waiting for the owner's permission to enter. It must be a situation where people are in imminent danger, evidence faces imminent destruction, or a suspect's escape is imminent. Once entry is obtained, the plain view doctrine applies, allowing the seizure of any evidence or contraband discovered in the course of actions consequent upon the exigent circumstances.

United States v. Place, 462 U.S. 696 (1983), was a decision by the Supreme Court of the United States in which the Court held, 9–0, that the sniff of one's personal property in a public place by a specially trained police dog was not a "search" under the meaning of the Fourth Amendment. In the case, Raymond Place had his luggage seized at LaGuardia Airport by agents with the Drug Enforcement Administration, which they held onto for several days while waiting for a search warrant to be granted. Justice Sandra Day O'Connor wrote for the unanimous Court that the sniff of a dog is sui generis, or "uniquely pervasive", and thus police do not need probable cause for their police dog to sniff a person's belongings in a public place. The Court did rule, however, that detaining a person's belongings while waiting for a police dog to arrive did constitute a "seizure" under the Fourth Amendment.

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Maryland v. Buie, 494 U.S. 325 (1990), was a decision by the Supreme Court of the United States handed down in 1990. In the case, the Court held that the Fourth Amendment permits a properly limited protective sweep in conjunction with an in-home arrest when the searching officer possesses a reasonable belief based on specific and articulable facts that the area to be swept harbors an individual posing a danger to those on the arrest scene.

Bailey v. United States, 568 U.S. 186 (2013), was a United States Supreme Court case concerning search and seizure. A 6–3 decision reversed the weapons conviction of a Long Island man who had been detained when police followed his vehicle after he left his apartment just before it was to be searched. Justice Anthony Kennedy wrote the majority opinion, and Antonin Scalia filed a concurrence. Stephen Breyer dissented.

<i>Florida v. Jardines</i> 2013 United States Supreme Court case

Florida v. Jardines, 569 U.S. 1 (2013), was a United States Supreme Court case which resulted in the decision that police use of a trained detection dog to sniff for narcotics on the front porch of a private home is a "search" within the meaning of the Fourth Amendment to the United States Constitution, and therefore, without consent, requires both probable cause and a search warrant.

United States v. Watson, 423 U.S. 411 (1976), was a case decided by the Supreme Court of the United States that decided that a warrantless arrest in public and consenting to a vehicle search did not violate the Fourth Amendment.

Johnson v. United States, 333 U.S. 10 (1948), was a significant United States Supreme Court decision addressing search warrants and the Fourth Amendment. In this case, where federal agents had probable cause to search a hotel room but did not obtain a warrant, the Court declared the search was "unreasonable."

References

  1. 1 2 3 4 5 6 7 8 9 10 11 Watson, G. Andrew (1981). "Fourth Amendment--Balancing the Interests in Third Party Home Arrests". Journal of Criminal Law & Criminology . 72 (4): 1263–75. doi:10.2307/1143233. JSTOR   1143233. Archived from the original on 2017-12-17.
  2. 1 2 3 U.S. Supreme Court (1981-01-14). "Oral argument in Steagald v. United States". Oyez Project . Archived from the original on 2017-12-23. Retrieved 2017-12-17. Alt URL
  3. 1 2 Kilpatrick, James (28 April 1981), "Supreme Court reaffirms a man's home is his castle", Times News, Twin Falls, Idaho, pp. A-4
  4. 1 2 3 4 5 6 7 United States v. Gaultney, 606F.2d540 ( 5th Cir .1979).
  5. 1 2 3 4 5 6 7 8 9 10 Steagald v. United States, 451US2014 (Supreme Court of the United States1981).
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