In relation to the facts of the case, a building harboring the Tylor’s Auction, a furniture store located in Oakland County, Michigan caught fire in the late night on 21 st January 1970. Loren Tyler operated the furniture store in collaboration with Robert Tompkins. When See, the fire chief arrived at the scene, he was informed about two plastic containers of flammable liquids that were found in the building. This suggested that arson might be the cause of the fire and Fire Chief See called Webb who was the police detective. On arrival, the police detective took pictures of the scene although the smoke and the steam could not allow further investigations. At around 4 a.m., the fire was put out and every day left the grounds. Webb got the containers although he did not have an authorization for the removal of the containers or access into the premises.
The Fire Chief returned into the scene the next morning accompanied by Assistant Chief Somerville who was to determine the causes of the fires that occur in his township. Their efforts involved conducting a cursory after which they left the scene. An hour later, the Assistant Chief returned accompanied by the detective police and after conducting some investigation they discovered evidence of arson. However, both had no permits for such seizures of evidence which could raise instances of dilemma in the future. This followed several visits including the visit by Sergeant Hoffman of the Michigan State police who secured more evidence of arson after conducting further investigations. This evidence could be used in the trial (Mussio, 1990).
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As the fact of the case, the respondents were subjected to the trial. However, the evidence introduced in the trial received an objection from the respondents but the judge admitted the evidence, which resulted in the respondents’ conviction. The State of Michigan’s court of Appeals held that the constitutional fortifications against illegal seizures and searches did not relate to arson investigations of burned stores and declared the conviction. In contrary, the Supreme Court of Michigan supported that the illegal investigation s and seizures were against the fourth and fourteenth amendments, which made the court reverse their convictions and ordered a new trial in return (Denenberg & Gordon, 1980).
Consequently, the facts legal question regarding the Court’s rationale and the dissenting opinion was as follows. Does the fourth and the fourteenth amendment protection against illegal seizures and searches extend to the investigations of the burned stores for the evidence supporting arson? Answers to the legal question received different opinions from the respective legislative officers. Justice Potter Stewart supported his opinion regarding the question supporting the court’s ruling as per the fourth amendments (Wright, 1990). He asserted that the Court requires that any search carried out for administrative purposes must have a warrant in order to conduct an investigation and find evidence of a given scene. However, there are circumstances that require detectives and other law enforcement agents to correct evidence without the permit. The judge gives an instance of firemen suggesting that they can seize evidence of arson that is in plain view even without a permit.
Moreover, the court asserts that determining the cause of fire in any given scene is among the duties of a fireman. Therefore, firemen could have remained in the building for investigations without warrant and correct evidence that could support a trial. In support of the ruling, the court held that the morning investigations and the initial entries were at per with the constitutional amendments. However, the subsequent seizures and entries into the fire scene were not constitutional hence supporting the ruling by the court (Mussio, 1990).
Justice John Paul, however, wrote a dissenting opinion that also concurred with the ruling on the first trial. In his opinion, Justice Paul agreed with the court’s finding concerning the illegal searches. However, he disagreed with the fact Court’s ruling the case on the basis of the warrant. In contrary, Justice John Paul urged that the warrant was necessary in a case where there was a feasible cause and the resulting search be ineffective. The permit clause used by the Court for the ruling required the premises owner to be given a fair warning relating to the search (Denenberg & Gordon, 1980).
Furthermore, Justice Bryon White wrote his opinion concurring part and dissenting part regarding the Court’s ruling on the reasonable amount of time for the evidence. The Justice argued that there was no reason behind considering the reentry of the building by the detectives and the personnel holding the evidence. Moreover, Justice William Rehnquist raised his dissenting opinion suggesting that most of the evidence and searches were reasonable hence did not require a permit. In addition, after the fire, Tylor could not use the building anymore a fact that rendered providing fair notice to him as a useless approach.
In conclusion, the Court’s rationale is based on the constitutional amendments. However, the dissenting and concurring opinions by the judges raise different opinions towards the ruling done by the Court. Most of the principles suggested by the judges affirmed the judgment made by the Michigan Supreme Court, which orders a new trial. In support of the case, most of the judges agree that investigations conducted in the fire scene are admissible at the second trial. However, if the investigating officials identify the probable cause that will fasten the belief that arson had taken place, then further access could be done for more evidence to support the prosecution (Mussio, 1990). Therefore, in such a case, they would obtain a warrant that will help in conducting further investigations.
References
Denenberg, J., & Gordon, I. (1980). The Exclusionary Rule in Civil Litigation: Sifting Through the Ashes of Michigan v. Tyler. Ins. Counsel J. , 47 , 375.
Mussio, D. (1990). Drawing the Line between Administrative and Criminal Searches: Defining the Object of the Search in Environmental Inspections. BC Envtl. Aff. L. Rev. , 18 , 185.
Wright, R. F. (1984). The civil and criminal methodologies of the Fourth Amendment. The Yale Law Journal , 93 (6), 1127-1146.
