Michigan v. Tyler Case Brief

Michigan v. Tyler, 436 U.S. 499, 98 S. Ct. 1942 (1978)

FACTS: On January 21, 1970, a fire broke out in Tyler’s Auction, a furniture store in Oakland County Michigan. Chief See arrived several hours later, as the firefighters were overhauling the structure. It was the Chief’s responsibility to determine the cause of the fire and complete all paperwork. The fire command officer reported that two containers of flammable liquid had been found. They entered the building briefly and the Chief determined that it could have been a case of arson. Chief See notified the police, and the detective (Webb) entered to take photographs, but had to step out because of the smoke and steam still remaining in the structure. Shortly afterward, the firefighters finished their work. The Chief and the police detective removed the two containers, which were placed in evidence for safekeeping. There was neither consent nor a warrant for the entries or the seizure.

Several hours later, Chief See and the Assistant Chief returned to the scene. Eventually, Webb arrived. Together they found suspicious burn marks on the carpet. They left briefly and returned with tools; they removed carpet and sections of the stairs with possible evidence of a fuse trail.

A couple of weeks later, Sgt. Hoffman of the Michigan State Police Arson Section returned to take photographs and search for additional evidence. Among other things, he found a length of fuse. He entered for the sole purpose of obtaining evidence.

Tyler objected to the entry of the evidence collected during these separate entries into the structure. The Michigan Supreme Court ruled that all entries after the fire was extinguished were not allowed, and reversed Tyler’s conviction.

ISSUE: Is entry into a fire-damaged property constitutional?

HOLDING: It depends.

DECISION: The Court stated that “there is no diminution in a person’s reasonable expectation of privacy nor in the protection of the Fourth Amendment simply because the official conducting the search wears the uniform of a firefighter rather than a policeman, or because his purpose is ascertain the cause of a fire rather than to look for evidence of a crime, or because the fire might have been started deliberately.” The Court went on to state that “[I]n the context of investigatory fire searches … a more particularized inquiry (into probable cause) may be necessary.” The purpose of the magistrate’s examination of the situation “can perform the important function of preventing harassment by keeping that invasion to a minimum.”

In taking each of the entries in turn, the Court agreed that entry into a burning building was clearly an exigent circumstance. Once inside the building lawfully to handle the fire, it is appropriate for the firefighters to seize and secure evidence in plain view. To that end, the seizure of the two containers by Chief See was lawful as well. The Court extended the Michigan’s Court’s interpretation, however, by stating that the exigency did not necessarily end when the last flame was extinguished, and stated that “officials need no warrant to remain in a building for a reasonable time to investigate the cause of a blaze after it has been extinguished. The Court held that the early morning entries by the firefighters and the police detective were simply a logical continuation of the earlier entries. However, the later entry by the Michigan State Police was too removed in time from the exigency and any evidence collected during that search should be excluded.