Steele v. United States
Citation and Court
267 U.S. 498 (1925) — Supreme Court of the United States
Facts
Federal agents obtained a warrant to seize cases of whiskey stored at a particular address. There was probable cause based on observation that cases of liquor were being moved to and from the premises. The warrant specified the location and described the property to be seized as intoxicating liquors.
Issue
Whether the warrant adequately described the place to be searched and the items to be seized, and whether probable cause supported issuance of the warrant.
Holding
The warrant was valid; the description of the place and items was sufficiently particular, and the observations supporting probable cause justified issuance of the warrant.
Rule / Doctrine
The Fourth Amendment’s Warrant Clause requires that warrants particularly describe both the place to be searched and the persons or things to be seized. Probable cause for a warrant to seize specific items exists when there is a fair probability, based on facts and circumstances, that the items will be found in the place to be searched. The particularity requirement prevents general, exploratory searches.
Significance
An early Supreme Court articulation of the warrant particularity requirement and the probable cause standard for item seizure. Established that probable cause is not a demanding standard but requires more than suspicion — specific facts supporting the inference that contraband will be found.