Legal Precedents and Fourth Amendment Implications in Michigan v. Tyler and Michigan v. Clifford

Introduction

Arson investigations are often complex procedures that involve not only the examination of the area but also the collection and seizure of the evidence to identify the origin and nature of the fire. However, in such instances, individuals are protected by the Constitution’s Fourth Amendment, which does not allow illegal seizure and search on the premises of a fire. Michigan v. Clifford and Michigan v. Tyler are helpful cases in establishing legal practices by differentiating between the search with and without a warrant, which determines whether the search is Constitutional.

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

The first case that occurred was Michigan v. Tyler in 1978. On January 21, a fire started in the respondents’ store, and the nearby fire station responded (U.S. Supreme Court, n.d.b). The finding of plastic canisters containing flammable substances was disclosed to the fire chief shortly after he reached the scene (U.S. Supreme Court, n.d.b).

As he entered the premises to investigate the vessels, he called a police investigator to examine the possibility of arson (U.S. Supreme Court, n.d.b). The smoke and heat forced the law enforcement officer to stop his inquiry after collecting multiple pictures (U.S. Supreme Court, n.d.b). However, what is noteworthy is that the investigation did not stop after leaving the premises after extinguishing the fire.

The examination and collection of the evidence proceeded on the following day. A staff member of the local police’s arson division visited the shop on February 16 and took pictures while conducting an examination (U.S. Supreme Court, n.d.b). This was followed by numerous subsequent inspections, at which time more proof and details were gathered (U.S. Supreme Court, n.d.b).

Respondents claimed no court order or permission was granted for the entry, examination, or confiscation (U.S. Supreme Court, n.d.b). According to the State Supreme Court’s ruling, “[once] the blaze [has been] extinguished and the firefighters have left the premises, a warrant is required to reenter and search the premises unless there is consent or the premises have been abandoned” (U.S. Supreme Court, n.d.b, para.2). Therefore. In contrast, being on the premises during the fire is not unlawful; the unauthorized presence and collection of evidence following the incident are not legal.

After closely analyzing the case, it is evident that, similar to regular building check regulations, a warrant in terms of fire investigation is necessary. The Fourth Amendment’s warrant requirements must be followed when making legally binding entries to investigate fire causes (Varone, 2022). All entries in the present instance were made without lawful approval and were not authorized by a legitimate investigative warrant, which means they are all unlawful (Varone, 2022). The rulings have acknowledged that when there is a critical need for official intervention and insufficient time to obtain a warrant for entry, an unauthorized visit by criminal law enforcement personnel may be legitimate.

A burning structure creates an emergency of sufficient scope to justify an unauthorized entry. It seems illogical to assume that firefighters must obtain a warrant or approval before entering a building on fire to extinguish the flames. Additionally, once inside a structure for this particular reason, firefighters may find and seize obvious arson evidence (Chandler, 2019).

Therefore, neither the entrance of the firefighters to put out the fire at Tyler’s Auction nor Chief See’s confiscation of both plastic containers of flammable substance discovered on the ground of the store breached the Fourth or Fourteenth Amendments (Varone, 2022). Thus, it can be affirmed that no court order is needed to enter a building to put out a fire and that authorities may stay there for an appropriate period to look into what started the fire (West, 2021). Following that, further records must be made by the warrant processes regulating administrative investigations to look into the origins of the fire.

Michigan v. Clifford, 464 U.S. 287 (1984)

Another incident, which occurred six years later, is Michigan v. Clifford. While the residence owners were away from the city, an ignition damaged the property (U.S. Supreme Court, n.d.a). At 7:04 a.m., emergency personnel put out the flames, and all police and fire personnel left the scene (U.S. Supreme Court, n.d.a).

Initially, a group of arson investigators visited the residence approximately five hours afterward to inquire about the fire’s origin (U.S. Supreme Court, n.d.a). A work team was covering the residence and draining water from the basement when they arrived (U.S. Supreme Court, n.d.a). The investigation team discovered that the respondents were made aware of the incident and had given their insurance agent instructions to dispatch a crew to protect the residence (U.S. Supreme Court, n.d.a). Despite this, the law enforcement officers entered the house and conducted a thorough search without obtaining permission or an administrative warrant (U.S. Supreme Court, n.d.a). However, in the given situation, all evidence collected can be removed from the case through the unauthorized search because it was gathered against their Fourth and Fourteenth Amendment rights.

The outcome of the case and the ruling were similar to the previous case. The Supreme Court ruled in Michigan v. Clifford that while fire investigation actions while firefighters are still on the job do not necessitate a warrant, the warrantless search after a 6-hour delay was unlawful under the Fourth Amendment (Ward, 2019). According to the court, after the fire and the authorities left, the property owner had an acceptable expectation of confidentiality (Purchase, 2019).

As a result, law enforcement had to adhere to the Fourth Amendment’s justifiable search requirements before a judge would issue either an administrative or criminal warrant for the search (Purchase, 2019). In Michigan v. Tyler, the fire officials departed the location once the temperature and time of day made it difficult to determine the fire’s nature and source (West, 2021). In contrast, in Michigan v. Clifford, it was claimed that they stayed on the scene until the water in the basement had been drained.

The critical point to be learned from both of these instances is that ownership of the site is crucial to execute a warrantless search for the fire’s origin. Reentering the scene to carry out the inquiry is impossible without the owner’s consent or an administrative search order if it has been abandoned (Dycus et al., 2020). The reason and origin investigation must stop immediately if an offense is believed to have occurred, and the police department must acquire a criminal search warrant while still maintaining custody of the property.

Conclusion

Hence, by distinguishing between searches conducted with and without a warrant, which decides whether the search is constitutional, the two cases help define legal practices. In Tyler v. Michigan, it was decided that legally authorized entries to investigate the causes of fires must comply with the warrant requirements established by the Fourth Amendment. In another event, Michigan v. Clifford, the ruling and outcome were similar to those in the prior instance. The Supreme Court decided that while fire extinguishing does not require a warrant, the warrantless search conducted after a 6-hour delay violated the Fourth Amendment.

References

U.S. Supreme Court. (n.d.a). Michigan v. Clifford, 464 U.S. 287 (1984). Web.

U.S. Supreme Court. (n.d.b). Michigan v. Tyler, 436 U.S. 499 (1978). Web.

Chandler, R. (2019). Fire investigations for first responders. Jones & Bartlett Learning.

Dycus, S., Vladeck, S. I., Banks, W. C., & Hansen, P. R. (2020). National security law. Wolters Kluwer.

Purchase, D. (2019). Chief officer: Principles and practice. Jones & Bartlett Learning.

Varone, J. C. (2022). Legal considerations for fire and emergency services. Fire Engineering Books & Videos.

Ward, M. J. (2019). Fire officer: Principles and practice. Jones & Bartlett Learning.

West, G. (2021). Legal aspects of emergency services. Jones & Bartlett Learning.