Law School Case Brief
Michigan v. Fisher - 558 U.S. 45, 130 S. Ct. 546 (2009)
The ultimate touchstone of the Fourth Amendment is reasonableness. Therefore, although searches and seizures inside a home without a warrant are presumptively unreasonable, that presumption can be overcome. For example, the exigencies of the situation may make the needs of law enforcement so compelling that the warrantless search is objectively reasonable.
Fisher was charged with assault with a dangerous weapon and possession of a firearm during the commission of a felony. Police responding to a domestic disturbance at respondent Fisher’s house found damaged property and blood at the scene, observed Fisher screaming and throwing things inside the house, and saw that his hand was cut. When Fisher refused to open the door or tell officers whether he needed medical attention, Officer Goolsby entered the house, where he found Fisher pointing a rifle at him. But the trial court suppressed Goolsby’s statement, ruling that the officer had violated the Fourth Amendment by entering the house without a warrant. The Michigan Court of Appeals affirmed
Was Police Officer Goolsby’s entry into the house, without a warrant, lawful?
It was objectively reasonable for the officers to have believed Fisher’s projectiles might have a human target, or that Fisher would hurt himself in his rage. It was plain that the officer's entry was reasonable under the Fourth Amendment. They did not need ironclad proof of "a likely serious, life-threatening" injury to invoke the emergency aid exception. The test was whether there was an objectively reasonable basis for believing that medical assistance was needed, or persons were in danger. The state court of appeals erred in replacing that objective inquiry into appearances with its hindsight determination that there was in fact no emergency. It sufficed to invoke the emergency aid exception based on a reasonable belief that defendant had hurt himself (albeit nonfatally) and needed treatment that in his rage he was unable to provide, or that he was about to hurt, or had already hurt, someone else.
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