In Michigan v. Tyler, 436 U.S. 499 (1978) the United States Supreme Court addressed the validity of several warrantless searches by investigators who sought to determine the cause of a suspicious building fire. In Tyler, firefighters arrived at the defendants' furniture store after a fire broke out shortly before midnight. Id. at 501. At approximately 2:00 a.m., the fire chief arrived at the scene and learned that firefighters saw plastic containers of flammable liquids inside the building as they were attempting to douse the flames. Id. at 501-502. The fire chief called a police detective and then entered the building to investigate the possibility of arson, but left the premises when smoke and steam interfered with his search. Id. at 502. At approximately 4:00 a.m., after firefighters extinguished the fire, the chief and detective entered the building without a warrant and removed the suspicious containers. Id. Between four and five hours later, the fire chief and detective again searched the building without a warrant and removed evidence, including carpeting and sections of a stairway. Id. In upholding the warrantless entry and re-entry of premises to determine the cause of a fire, the Court recognized that fire officials are charged not only with extinguishing fires, but also with finding their causes. The Court observed: "Immediate investigation may also be necessary to preserve evidence from intentional or accidental destruction." Id. at 510. The Court then recognized that it was necessary for the officials to remain in the building a "reasonable" time "pursuing their duty both to extinguish the fire and to ascertain its origin." Id. In Michigan v. Tyler, the fire chief testified that their job was to respond to the fire and "to determine its cause and make out all reports." Id. at 501