> For the complete documentation index, see [llms.txt](https://studies-de-jure.gitbook.io/learn/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://studies-de-jure.gitbook.io/learn/sourcebooks/criminal-procedure/arrests/cases-warrants-and-in-home-arrests/steagald-v.-united-states/steagald-v.-united-states-1981.md). # Case Brief—Steagald DEA had arrest warrant Ricky Lyons Agents entered petitioner Gary Steagald's home to **search** for **and arrest** Lyons without first obtaining a **search warrant**. Officers talked to two men outside the house. They approached with guns drawn, frisked both men, and determined that neither of them were Lyons. Several agents proceeded to the house. Gaultney’s wife answered the door, and informed the agents that she was alone in the house. She was told to place her hands against the wall and was guarded in that position while one agent searched the house. During the search, agents found cocaine and other incriminating evidence, but did not find Lyons. Steagald arrested and indicted on federal drug charges. Steagald argued that the search violated the 4th Amendment ## Issue Whether a law enforcement officer may legally search for the subject of an arrest warrant in the home of a third party without first obtaining a search warrant (absent exigent circs or consent) ## Held Nope ## Rule search warrant must be obtained absent exigent circumstances or consent * **Two distinct interests** were implicated by the search in this case * interest in being free from an unreasonable seizure **and** petitioner's interest in being free from an unreasonable search of his home. ## Analysis * Arrest warrant addressed only the interest in being free from an unreasonable seizure, not being free from an unreasonable search of the home * A search warrant requirement, under the circumstances of this case, will not significantly impede effective law enforcement efforts. * An arrest warrant alone suffices to ***enter a suspect's own residence***, and, if probable cause exists, no warrant is required to apprehend a suspected felon in a public place. * Exigent circumstances doctrine significantly limits the situations in which a search warrant is needed. * In practice, inconvenience incurred by the police in obtaining a search warrantis generally insignificant. * Interests of Steagald outweighs the interest in warrantles entry into Steagald's home to arrest someone who doesn't live there ## Dissent * Majority ignores the critical fact in this case: the existence of an **arrest warrant** for a fugitive believed on the basis of **probable cause to be in the dwelling**. * The Court assumes the arrest warrant wasn't a relevant justification it failed to Steagald's privacy interest * but a valid arrest warrant requires PC that the person is in the place of arresarrest * Thus, the intrusion was merely incidental to executing the arrest warrant * Should be a balncing that includes government's compelling interests in the warrantless entry of a third-party dwelling to execute an arrest warrant * requiring the search warrant frustrates the purpose of the arrest warrant and the practical realities of apprehending fugitives * e.g., inherent mobility of fugitives and difficulties in assessing how long the fugitive would be in on place * privacy interest of the 3rd party is not as signifant has the majority claims * warrant = * notice of official business * intrinsic limited scope of a search * suspect might surrender * 3rd party might indicate suspect's location in the home * plain view seizure was during sweep, not an intrusive search * burden on obtain warrant to much given a high risk of fugitives escaping --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://studies-de-jure.gitbook.io/learn/sourcebooks/criminal-procedure/arrests/cases-warrants-and-in-home-arrests/steagald-v.-united-states/steagald-v.-united-states-1981.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.