People v. Slaughter
489 Mich. 302
| Mich. | 2011Background
- Tunner called 911 after seeing water leaking between a shared wall and an electrical box, signaling a potential life/property hazard.
- Royal Oak firefighters, including Lieutenant Schunck, entered defendant Slaughter's townhouse to locate the water issue and assess fire risk.
- Schunck entered through a window to access the unit, shut off water from the basement, and observed marijuana plants in plain view.
- Police later secured a warrant; officers seized 48 marijuana plants, grow lights, and related paraphernalia inside the home.
- The district court bound Slaughter over but the circuit court granted suppression, ruling the entry violated the Fourth Amendment and that Schunck acted without sufficient basis.
- The Court of Appeals affirmed the suppression on alternative grounds; the Michigan Supreme Court reversed, holding firefighters may invoke the community caretaking exception and the entry was reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the community caretaking exception extends to firefighters | Plaintiff argues the exception applies to firefighters. | Defendant argues the exception does not justify entry into a home. | Yes; firefighters may invoke the community caretaking exception. |
| Whether the firefighter's entry was reasonable under the exception | Schunck acted with reasonable belief to abate an imminent fire threat. | The entry was unreasonably intrusive and not properly justified. | Yes; the entry was reasonable under the community caretaking framework. |
| Scope and limits of a firefighter's entry under the exception | Entry must be within the scope necessary to abate the threat and not exceed it. | Entry could be broader and not properly limited by necessity. | Entry limited to reasonable scope and duration necessary to assess/abate the threat. |
Key Cases Cited
- Cady v. Dombrowski, 413 U.S. 433 (1973) (establishes the community caretaking function doctrine in automobile contexts)
- Michigan v. Tyler, 436 U.S. 499 (1978) (no warrant required for firefighters to enter to fight a fire in progress)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (no warrant needed to enter a residence to assist those in danger; emergency-invoked premises)
- People v. Davis, 442 Mich. 1 (1993) (discusses community caretaking and emergency aid; distinguishes home vs. automobile contexts; emergency-aid standard applies to homes)
- Camara v. Muni Court of City & Co. of San Francisco, 387 U.S. 523 (1967) (administrative search framework; distinction between well-delineated exceptions and general caretaking)