Did the arrest warrant for Croy allow the deputies to enter Looney’s residence in search of Croy?
To answer this issue, the court looked to the case of Steagald v. United Statesii, decided in 1981, by the United States Supreme Court. In this case, DEA agents received a tip that a federal fugitive was located in Steagald’s house, although the fugitive did not live with Steagald. The agents went to Steagald’s home and searched for the fugitive, whom they did not locate. However, they did observe cocaine and Steagald was charged. Ultimately, the Supreme Court heard the case in order to decide whether officers could enter a third party’s residence to search for a wanted person. The Supreme Court held that, unless officers have the consent of the resident or exigent circumstances are present, they must obtain a search warrant to enter a third party’s residence to search for a wanted person. Thus, the entry in Steagald, which was not based on consent or exigent circumstances, violated the Fourth Amendment. The court also noted that, in Payton v. New Yorkiii, the Supreme Court held that o
