Facts
- DEA agents held a federal arrest warrant for Ricky Lyons on drug charges.
- Agents traced a telephone number associated with Lyons to an address that was Gary Keith Steagald’s residence in Georgia.
- Agents encountered Steagald and another man outside, frisked them, and determined neither was Lyons.
- Despite being told no one else was inside, agents entered Steagald’s home and searched for Lyons without a search warrant, consent, or exigent circumstances.
- Lyons was not found; agents observed suspected cocaine during the entry.
- Agents sought a search warrant after seeing the suspected cocaine, continued searching while it was obtained, and then searched again after issuance, seizing cocaine and paraphernalia.
- Steagald was indicted and convicted on federal drug charges after the trial court denied his motion to suppress.
- The court of appeals affirmed; the Supreme Court granted review.
Issues
- Whether an arrest warrant for a suspect authorizes officers to enter and search a third party’s home for the suspect without a search warrant, absent consent or exigent circumstances.
- Whether the Government could argue for the first time on review that the homeowner lacked a Fourth Amendment privacy interest in the searched residence.
Decision
- The Supreme Court reversed and remanded.
- The Court held that an arrest warrant alone does not justify entry into and search of a third party’s home; a search warrant is required absent consent or exigent circumstances.
- The Court declined to consider the Government’s belated argument that Steagald lacked a protected privacy interest because it was not raised below and contradicted the Government’s earlier position.
Legal Principles
- The Fourth Amendment generally requires a warrant to enter and search a home; exceptions are limited to recognized doctrines such as consent or exigent circumstances.
- An arrest warrant protects the suspect’s interest against unreasonable seizure, but it does not authorize intrusion into a third party’s home, which implicates the third party’s separate privacy interest against unreasonable searches.
- When officers seek to look for the subject of an arrest warrant inside a residence not belonging to the subject, a search warrant is required unless an exception applies.
- The Government may be barred from raising a Fourth Amendment “no privacy interest/no standing” argument on review when it failed to raise it in lower courts and proceeded on contrary assumptions there.
Conclusion
The Court required a search warrant, not merely an arrest warrant, for police to enter and search a third party’s home for a suspect, unless consent or exigent circumstances justify the intrusion; because neither exception applied, the search violated the Fourth Amendment and the conviction could not stand on the seized evidence.