Michigan v. Tyler

RESPONDENT: Loren Tyler and Robert Tompkins
LOCATION: Oakland County, Michigan

DOCKET NO.: 76-1608
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: Michigan Supreme Court

CITATION: 436 US 499 (1978)
ARGUED: Jan 10, 1978
DECIDED: May 31, 1978
GRANTED: Oct 03, 1977

Jesse R. Bacalis - for respondents
Jeffrey Butler - for petitioner, pro hac vice, by special leave of Court

Facts of the case

On January 21, 1970, Tyler’s Auction, a store located in Oakland County, Michigan, was burned up before midnight. Loren Tyler rented out the building to conduct the business together with Robert Tompkins. When See, the fire Chief, came to the place of the accident, he got to know that two plastic boxes were discovered in the establishment. They contained some burnable liquid and caused probably the burning. Then See called for police. When the officer Webb came, he made the photos, but the smoke and soot didn’t allow him to continue the investigation. Near four a. m. the fire was put out, the boxes were handed over to Webb. However, the officer did not possess a warrant for examination and seizure of any items from the house.

The next day See came to the place of the accident with Somerville, assistant chief, who was worked on the resolving the problem regarding the causes of all fires happens in the Township. They observed the store, and in the hour after came back with Webb found out the proof of the existence of arson. The officers had no warrants to conduct these investigations or seizures of items. They also performed few more examinations and provided the other proof of arson that had a key role at the court.

During the trial, the respondent, Tyler, argued regarding the consideration of these proofs, but the court accepted them and condemned the defendant. The appellate court confirmed the previous opinion finding that the constitutional guarantees did not prohibit examinations of the burned buildings. The Supreme Court of the State upheld in Michigan v Tyler that these investigations were conducted with the breach of Fourth and Fourteen Amendments as the officers had no legal permission for its exercising.

However, the appellant brought a claim before the Supreme Court of the USA to resolve the issue whether the jurisdiction of constitutional guarantees was extended to the investigations of the accidents of the burning of buildings.

The Court stated that under the law any the examinations should be confirmed by the warrant. But in the urgent conditions like the firing, the officer had the right to conduct observation without the issued permission. Thus, the evidence obtained in Michigan vs. Tyler after the first examination by the fireman were accepted as they were seized as result of the fireman`s responsibilities and he had the right to stayed in the premises for a consent period of time to observe the place. But the judges refused to consider next examinations and obtained evidence as they were not confirmed by the legal grounds. The judgment cited Marshall v. [436 U.S. 499, 512] Barlow's Inc. that confirmed that supplementary investigations of the reasons of the fire should be conducted accordingly to the warrant rules of administrative observations.

Hence, the Court upheld the acceptance of the first evidence but considered as invalid the further ones and ordered the revising of the so-called Tyler case.


Does the Fourth Amendment protection against illegal searches and seizures extend to investigations of burned premises for evidence of arson?

Media for Michigan v. Tyler

Audio Transcription for Oral Argument - January 10, 1978 in Michigan v. Tyler

Audio Transcription for Opinion Announcement - May 31, 1978 in Michigan v. Tyler

William J. Brennan, Jr.:

The opinion and judgment in 76-1608, Michigan v. Tyler will be announced by Mr. Justice Stewart.

Potter Stewart:

This case is here by reason of the grant of a writ of certiorari to the Supreme Court of Michigan.

The respondents, Loren Tyler and Robert Tompkins were convicted in a Michigan trial court of conspiracy to burn real property in violation of a state criminal law.

Various pieces of physical evidence and testimony based on personal observation all obtained through un-consented and warrantless earaches and entries by police and fire officials onto the burned premises were admitted into evidence at the respondents' trial.

On appeal the Michigan Supreme Court reversed the convictions, holding that the warrantless searches were unconstitutional and that the evidence obtained was therefore inadmissible.

We granted certiorari to consider the applicability of the Fourth and Fourteenth Amendments to official entries onto fire damaged premises.

For the reasons set out in the written opinion of the Court, filed with the clerk this morning, we hold that an entry into a building to fight a fire requires no warrant and that once in the building, officials may remain there for a reasonable time to investigate the cause of the fire.

Thereafter, additional entries to investigate the cause of the fire must be made pursuant to the warrant procedures governing administrative searches.

Evidence of arson discovered in the course of these investigations is admissible at trial, but if the investigating officials find the probable cause to believe arson has occurred and require further access to gather evidence for a possible prosecution, they may obtain a warrant only upon a traditional showing of probable cause applicable to searches for evidence of crime.

These principles require that we affirm the judgment of the Michigan Supreme Court, ordering a new trial.

Mr. Justice Blackmun has filed a separate statement joining the judgment and most of the opinion.

Mr. Justice White joined by Mr. Justice Marshall has filed an opinion concurring in part and dissenting in part.

Mr. Justice Stevens has filed an opinion concurring in part and concurring in the judgment.

Mr. Justice Rehnquist has filed a dissenting opinion and Mr. Justice Brennan took no part in the consideration or decision of the case.