Michigan v. Fisher
558 U.S. 45 (2009)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under the Fourth Amendment's emergency aid exception, law enforcement may enter a home without a warrant if they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury, even without ironclad proof of a life-threatening situation.
Facts:
- Police officers responded to a complaint about a disturbance.
- Upon arriving at Jeremy Fisher's residence, officers observed a pickup truck with a smashed front, damaged fenceposts, and three broken house windows.
- The officers noticed blood on the hood of the truck, on clothes inside it, and on one of the house doors.
- Through a window, officers saw Fisher inside the house, screaming and throwing things.
- The officers saw that Fisher had a cut on his hand.
- When officers knocked, Fisher refused to answer and demanded they get a search warrant.
Procedural Posture:
- Jeremy Fisher was charged in a Michigan state trial court with assault with a dangerous weapon and a felony-firearm offense.
- The trial court granted Fisher's motion to suppress evidence resulting from the officer's entry, finding the entry violated the Fourth Amendment.
- The Michigan Court of Appeals, an intermediate appellate court, initially remanded for a full evidentiary hearing.
- On remand, the trial court held the hearing and reinstated its order to suppress the evidence.
- The Michigan Court of Appeals affirmed the trial court's suppression order.
- The Michigan Supreme Court, the state's highest court, initially granted leave to appeal but later vacated its order and denied leave.
- The State of Michigan (petitioner) sought a writ of certiorari from the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a police officer's warrantless entry into a home violate the Fourth Amendment when the officer, responding to a disturbance, observes significant property damage, blood, and a tumultuous scene with an individual inside acting erratically?
Opinions:
Majority - Per Curiam
No. The officer's entry did not violate the Fourth Amendment because the emergency aid exception allows for a warrantless entry when there is an objectively reasonable basis to believe a person inside is in need of immediate aid or is in imminent danger. The officers were confronted with a chaotic scene: a smashed truck, broken windows, blood, and Fisher screaming and throwing objects inside. These circumstances were sufficient to provide an objectively reasonable basis for believing that Fisher had hurt himself and was in need of aid, or that he was about to hurt, or had already hurt, someone else. The Michigan court erred by requiring officers to have 'ironclad proof of a likely serious, life-threatening injury,' as the Fourth Amendment's reasonableness standard does not demand such a high level of certainty. The proper inquiry is not a hindsight determination of whether an emergency actually existed, but whether the facts as they appeared at the moment of entry would lead a reasonable officer to believe assistance was needed.
Dissenting - Justice Stevens
Yes. The officer's entry violated the Fourth Amendment because the State failed to meet its burden of proving that the officer had an objectively reasonable basis to believe Fisher was seriously injured or imminently threatened with such injury. The trial judge, who heard the officer's testimony, found the evidence—'mere drops' of blood and Fisher's coherent refusal to allow entry—insufficient to justify a warrantless intrusion. The Supreme Court is not justified in micromanaging the day-to-day business of state tribunals and usurping the role of the factfinder, particularly in a case involving a fact-intensive reasonableness inquiry. Deference should have been given to the trial court's finding that no true emergency existed.
Analysis:
This decision reinforces and clarifies the 'emergency aid' exception established in Brigham City v. Stuart. The Court emphasizes that the standard is purely objective reasonableness, viewed from the perspective of an officer on the scene, not through the lens of hindsight. By rejecting the Michigan court's requirement for evidence of a 'life-threatening' injury, the ruling lowers the threshold for what constitutes an emergency, granting law enforcement greater latitude to enter homes without warrants in volatile situations. This precedent instructs lower courts to avoid second-guessing an officer's on-the-spot judgment when there are clear signs of chaos and potential injury.
Unlock the full brief for Michigan v. Fisher