In Zurcher v. Stanford Daily, 436 U.S. 547 (1978), the Court stated that searches of property belonging to persons not suspected of crime are permissible as long as probable cause exists. In the case Steagald v. U.S., 451 U.S. 204 (1981), the Court found that an arrest warrant is valid for entry into a suspect's place of residence, however, it does not authorize entry into another person's residence. A warrant which is overbroad in describing the place to be searched based on a reasonable but mistaken belief of the officer is not in violation of the fourth amendment, as stated in Maryland v. Garrison, 480 U.S. 79 (1987). In the case California v. Greenwood, 486 U.S. 35 (1988), it was found that a warrantless search and seizure of trash left for collection in an area accessible to the public is permitted. Seizure is addressed in the cases Michigan v. Chesternut, 486 U.S. 567 (1988), where the appropriate test to determine if a seizure has occurred is whether a reasonable man would conclude that he is not free to leave, and Brower v. County of Inyo, 109 S.Ct. 1378 (1989), where a seizure occurs when there is a "governmental termination of freedom of movement through means intentionally applied."