Sunday, January 4, 1998

US Supreme Court Steagald v. US 79-6777

Decision here.
4-21-81

   The facts: Lyons had a warrant for his arrest.  DEA agents received an anonymous tip which led them to Steagald's house.  They spent a couple of days planning the raid, but they didn't get a search warrant because they expected Lyons' arrest warrant to justify entry into the house.  Agents went to Steagald's house, gunpointed everybody and searched for Lyons.  They didn't find him, but they found cocaine.  They searched again while applying for a warrant, and found more evidence.  When the warrant was issued, they searched a third time and found a lot of cocaine.  Lyons wasn't found, as has no further relevance to this case.  Steagald was convicted of federal drug offenses, and appealed his conviction on the grounds that the entry and search of his house violated the fourth amendment.

   In Payton, the court had held that an arrest warrant allows the police to make entry into the defendant's home in order to arrest him, when there is reason to believe that he is within.  When an arrest warrant has been obtained, the defendant's right to be free from unreasonable search and seizure is already protected by involving the detached scrutiny of a judicial officer.  But that's when the defendant is arrested in his own home.  In this case, the court pointed out that a warrant for Lyons' arrest did nothing to protect Steagald from unreasonable search and seizure.  The court compared using an arrest warrant to justify a search of someone else's house to the writs of assistance which the Fourth Amendment was originally designed to prevent.  In order to render the search reasonable in the instant case, the agents would have had to obtain a search warrant for Steagald's house.

   This decision doesn't diminish police authority to make entry where there are exigent circumstances, or to make arrests in a public place.

2 comments:

  1. Chalk this one up in the "had to be said" column :)

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    Replies
    1. LOL!

      Now, if only more people knew that it had been said.

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