MICHIGAN V. FISHER, 558 U.S. 45 (2009).
Officers who responded to a disturbance in a house entered the house without a warrant. Before entering the house, the officers observed damaged property and blood stains outside the house. Additionally, from outside the house, the officers could the the defendant in the house screaming and throwing things. Defendant argued that the officers entry into the house without a warrant violated his fourth amendment rights.
Held: Officers entry into the house without a warrant did not violate the defendants right because the officers had an objectively reasonable basis for believing that a person within the house may be in need of immediate aid. This emergency aid exception does not depend on the officers’ subjective intent or the seriousness of any crime they are investigating when the emergency arises.
Police officers responded to a complaint of a disturbance near Allen Road in Brownstown, Michigan. Officer Christopher Goolsby later testified that, as he and his partner approached the area, a couple directed them to a residence where a man was “going crazy.”
Upon their arrival, the officers found a household in considerable chaos: The officer saw a pickup truck in the driveway with its front smashed, damaged fenceposts along the side of the property, and three broken house windows with the glass still on the ground outside. The officers also noticed blood on the hood of the pickup and on clothes inside of it, as well as on one of the doors to the house. (It is disputed whether they noticed this immediately upon reaching the house, but undisputed that they noticed it before the allegedly unconstitutional entry.)
Through a window, the officers could see defendant, Jeremy Fisher, inside the house, screaming and throwing things. The back door was locked, and a couch had been placed to block the front door.
The officers knocked, but Fisher refused to answer. They saw that Fisher had a cut on his hand, and they asked him whether he needed medical attention. Fisher ignored these questions and demanded, with accompanying profanity, that the officers go to get a search warrant. Officer Goolsby then pushed the front door partway open and ventured into the house. Through the window of the open door he saw Fisher pointing a long gun at him. Officer Goolsby withdrew.
Fisher was charged under Michigan law with assault with a dangerous weapon and possession of a firearm during the commission of a felony. The trial court concluded that Officer Goolsby violated the Fourth Amendment when he entered Fisher’s house, and granted Fisher’s motion to suppress the evidence obtained as a result— that is, Officer Goolsby’s statement that Fisher pointed a rifle at him.
Whether the officer violated the fourth amendment when he entered the defendants residence without a warrant.
Law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury. This emergency aid exception does not depend on the officers’ subjective intent or the seriousness of any crime they are investigating when the emergency arises. It requires only an objectively reasonable basis for believing, that a person within [the house] is in need of immediate aid.
A straightforward application of the emergency aid exception, dictates that the officer’s entry was reasonable. The police officers here were responding to a report of a disturbance. When they arrived on the scene they encountered a tumultuous situation in the house, and they found signs of a recent injury, perhaps from a car accident, outside. The officers could see violent behavior inside. Although Officer Goolsby and his partner did not see punches thrown, they did see Fisher screaming and throwing things. It would be objectively reasonable to believe that Fisher’s projectiles might have a human target (perhaps a spouse or a child), or that Fisher would hurt himself in the course of his rage. In short, we find it as plain here that the officer’s entry was reasonable under the Fourth Amendment.
The Michigan Court of Appeals, however, thought the situation did not rise to a level of emergency justifying the warrantless intrusion into a residence. Although the Court of Appeals conceded that there was evidence an injured person was on the premises, it found it significant that the mere drops of blood did not signal a likely serious, life-threatening injury. The court added that the cut Officer Goolsby observed on Fisher’s hand likely explained the trail of blood” and that Fisher was very much on his feet and apparently able to see to his own needs.
But the supreme court disagreed.
The supreme court reasoned that the officers do not need ironclad proof of “a likely serious, life-threatening” injury to invoke the emergency aid exception.
Fisher however argued that the officers could not have been motivated by a perceived need to provide medical assistance, since they never summoned emergency medical personnel.
But the court explained that this would have no bearing, of course, upon their need to ensure that Fisher was not endangering someone else in the house. Moreover, even if the failure to summon medical personnel conclusively established that Goolsby did not subjectively believe, when he entered the house, that Fisher or someone else was seriously injured (which is doubtful), the test, as we have said, is not what Goolsby believed, but whether there was “an objectively reasonable basis for believing” that medical assistance was needed, or persons were in danger
It was error for the Michigan Court of Appeals to replace that objective inquiry into appearances with its hindsight determination that there was in fact no emergency. It does not meet the needs of law enforcement or the demands of public safety to require officers to walk away from a situation like the one they encountered here. Only when an apparent threat has become an actual harm can officers rule out innocuous explanations for ominous circumstances. But the role of a peace officer includes preventing violence and restoring order, not simply rendering first aid to casualties. It sufficed to invoke the emergency aid exception that it was reasonable to believe that Fisher had hurt himself (albeit nonfatally) and needed treatment that in his rage he was unable to provide, or that Fisher was about to hurt, or had already hurt, someone else. The Michigan Court of Appeals required more than what the Fourth Amendment demands.
The officer did not violate Fishers fourth amendment right because he had an objectively reasonable basis to believe that Fisher or someone else might be in need of aid.