Previous decisions regarding warrantless entries to make felony arrests had left undecided the issues that arise when police enter the home of a person other than the one to be arrested. In the Steagald case, agents of the Drug Enforcement Agency had an arrest warrant for a Federal fugitive, Ricky Lyons. Probable cause existed to believe that Lyons could be found in a residence occupied by Steagald. The agents made an armed entry, eventually seized 43 pounds of cocaine, and produced a conviction of Steagald for its possession. Lyons was not found. The Supreme Court held that an arrest warrant was not sufficient for entering a third party's residence and that a search warrant was required. The arrest warrant protected Lyon's interest but not Steagald's interest in freedom from unreasonable searches of his home, according to the Court. The Steagald rule is most likely to be applied in a private lawsuit and contains substantial limits. In North Carolina, the Attorney General's Office favors the application of the rule by considering the defendant an 'item' under the State's G.S. 15A-242. Law enforcement officers generally must have a valid search warrant to enter a third party's home to make an arrest. With the consent of the householder, they may enter a dwelling for either a search or an arrest without a search warrant. Exigent circumstances and probable cause must be present to enter a dwelling to make an arrest without a search warrant. They need a search warrant to enter a third party home to arrest a defendant. Fourteen footnotes and a sample application for a search warrant are included.