The majority of Circuit Courts have interpreted reasonable belief as a functional equivalent of probable cause with regards to entering into a dwelling. In Steagald, the court held that, absent exigent circumstances, a search warrant is required to enter a third party’s residence in order to search for a fugitive believed to be within. Steagald v. United States, 451 U.S. 204, 222 (1981). This conclusion arose from the facts that officers entered into Steagald’s home looking for Ricky Lyons, a person not living in Steagald’s house, with only an arrest warrant. Id. at 206. The Supreme Court reasoned that the arrest warrant alone was not sufficient enough to allow the entry in Steagald’s house; the probable cause determination of a neutral magistrate that Lyons would be within the house was necessary to allow the officers to search the house for Lyons. Id. at …show more content…
This rule equates the standards needed for probable cause to be that of reasonable belief, but claims reasonable belief is the standard only after a warrant has already been secured. Id. This is because, as the Payton Court further explained, “an arrest warrant founded on probable cause, implicitly carries with it the limited authority to enter into a dwelling in which the suspect lives when there is a reason to believe the suspect is within.” Payton v. New York, 445 U.S. 573, 603 (1980) (emphasis added). The Woods court appears to equate the standards necessary for probable cause with those necessary for reasonable belief, and only changes the terms after a warrant is acquired. United States v. Woods, 560 F.2d 660, 665 (5th. Cir 1977). Woods and Edmunds concerned similar issues. In Edmunds, officers knocked and did not receive a response. After waiting, the officers heard a voice inside the apartment and forcibly entered. In Woods, officers entered a dwelling to execute an arrest warrant, after a door “sprang open.” Id. at 662. Consent was not obtained in either