In American law enforcement, certain cases stand out as pivotal moments that redefine practices and procedures. One such landmark case is Steagald v. United States that is centered around the issue of entering a residence to arrest a wanted individual. Lets dive deeper into the case, discover its lasting implications, and learn how to write successful Steagald warrants.
The Background: Steagald v. United States
In January 1978, a confidential source provided information to the Detroit Drug Enforcement Administration (DEA) about Ricky Lyons, a fugitive with a federal arrest warrant. The informant provided a phone number where Lyons could be reached within the next day. Using the phone number, The DEA identified an address: a lakeside cabin in Buford, Georgia. Accompanied by eleven officers and agents, the DEA went there to capture Lyons.
At the cabin, Agents met Hoyt Gaultney and Gary Keith Steagald who were outside working on a car; neither was Lyons. Agents approached the residence and spoke to Gaultney’s wife, Cathy, who confirmed no one else was in the house. Despite this, officers entered and searched the home. They didn’t find Lyons but stumbled upon some cocaine.
The case agent decided to get a search warrant and, while waiting, conducted a second search and found even more cocaine. After obtaining the warrant, a thorough search revealed about 43 pounds of high-purity cocaine, worth around $2.5 million. This cocaine, hidden inside decorative brass items, was traced back to Colombia.
Both Gaultney and Steagald faced federal drug charges. During the search, James “Jimmy” Albert Smith, the house’s lessee with his own drug-related arrest warrant, arrived and was promptly arrested.
Central Issue:
The crux of the case before the Supreme Court was to determine the scope and limitations of an arrest warrant, especially concerning third-party residences. Specifically, the Court was tasked with answering: Does an arrest warrant for a wanted individual permit law enforcement officers to search a third party’s home for that individual, even if they do not have a separate search warrant for the premises?
The Verdict: A Resounding Emphasis on Fourth Amendment Rights
Steagald requested the trial court to exclude the evidence found during the search without a warrant. However, the court rejected this and both Gualtney and Steagald were found guilty. Following their conviction, they sought a mistrial, but this too was denied. They then appealed their convictions to the United States Court of Appeals for the Fifth Circuit who, in a split 2-1 decision, upheld the convictions. They based their decision on a previous case, United States v. Cravero, which stated that if an officer has a valid arrest warrant and reasonably believes the person named in the warrant is in a third party’s property, they don’t need a separate search warrant to enter and arrest the individual.
Unsatisfied, Steagald took his case to the Supreme Court. The Supreme Court agreed to review the case, focusing on the question of whether law enforcement can search a third-party’s home using only an arrest warrant, without the homeowner’s permission. The Supreme Court sided with Steagald.
The Court firmly established that an arrest warrant for a wanted individual does not, under any circumstance, grant law enforcement the authority to search a third party’s home for that individual. To do so, they would need a separate search warrant, one that is rooted in probable cause, indicating that the wanted individual is present in that third party’s residence.
Limitations to the Search Warrant
While the Steagald decision brought clarity to the need for a search warrant, it is important to understand its limitations. A search warrant and an order from the court allowing police to go to a place and collect a thing. A Steagald warrant is a residential warrant where the thing is a wanted person. A Steagald Warrant is narrowly focused and must address the following:
- The identity of the wanted person.
- The wanted person has an active arrest warrant and what they are wanted for.
- Where the wanted person is believed to be.
- That the location is not owned or controlled by the wanted person.
- What direct information and specific facts establish them being there presently.
For tips on writing residential search warrants, check out of Understanding Search Warrants series: Residential Warrants.
Plain View Searches During Steagald Arrests
It is important to note that the Steagald warrant authorizes Law Enforcement to enter the third party residence for the limited purpose of collecting the wanted person. So what about illegal items or evidence that can be seen in plain view? The Steagald decision does not require Officers to wear blinders. If the DEA had secured a warrant to enter Steagald’s home to collect Lyons, and the cocaine was simply lying on a table in plain view, Steagald would still have been subject to arrest and prosecution. However, after the wanted person has been captured, a Steagald warrant is not intended to allow Officers to linger and use their time leaving the residence to visually search for evidence of a different crime.
In the event that evidence of a different crime is observed by plain view, the Steagald warrant cannot expand to allow the collection of that evidence. An additional search warrant must be secured based on the information discovered and described in the probable cause affidavit.
Conclusion
A man’s home is his castle and law enforcement should always consider the 4th Amendment implications of of their intrusion into a person’s home. Steagald V. US set the requirement for police to have a search warrant to enter a third party residence to effect the arrest of a wanted person. The key to writing a successful Steagald warrant is understanding the limited intrusion on the home of an uninvolved party and what you are allowed to do once you are in the residence.
