Michigan v. Clifford

In Michigan v. Clifford, 464 U.S. 287 (1984) the Court, by Justice Powell, held that where a residence was damaged by fire while owners were out of town that post fire searches are not exempt from a warrant requirement. Five hours after fire officials and police left the premises, a team of arson investigators arrived conducting a warrantless search, without consent, to investigate the cause of the fire. They began in the basement where they found two Coleman fuel cans and a crock pot attached to an electrical timer. The investigators then searched the upstairs of the premises finding additional evidence of arson. The Court in Michigan v. Clifford, supra, reasoned that it had "frequently noted that privacy interests are especially strong in a private residence."