In Steagald v. United States (1980), the U.S. Supreme Court ruled that law enforcement officers must obtain a search warrant to search a third party's home for the subject of an arrest warrant, unless there are exigent circumstances or consent is given. The case arose when federal agents entered Gary Steagald's house without his permission and without a search warrant while looking for another individual named Ricky Lyons, who was not present at the time but was wanted on drug charges. Instead, they found cocaine in Steagald’s residence and arrested him based on this discovery. In its decision, the court held that such searches violated Fourth Amendment protections against unreasonable searches and seizures because it did not respect an individual's privacy rights in their own home.

In the dissenting opinion for Steagald v. United States, Justice Powell argued that the majority's decision unnecessarily complicated law enforcement procedures and potentially endangered officers' lives. He believed that a warrant to arrest should be sufficient legal basis for police to enter a third party's home if they have reasonable belief that the suspect is present there. The requirement of an additional search warrant, he contended, would delay apprehension of criminals and could lead to destruction of evidence or escape attempts by suspects alerted by police presence outside their refuge. Furthermore, it might expose officers to unnecessary danger as they wait for issuance of a second warrant while potential threats remain inside the house unchecked. Justice Powell also pointed out inconsistencies in majority’s reasoning regarding privacy rights protection – on one hand allowing entry without any warrants when pursuing fleeing felons but requiring two separate warrants in other situations.