State v. Bell
In State v. Bell, 108 Wn.2d 193, 737 P.2d 254 (Wash. 1987), firefighters discovered a marijuana-growing operation at a fire scene while searching an attic to determine if there were smoldering embers. A deputy sheriff was called to assist in the removal of the marijuana.
The court held that "where firefighters have lawfully discovered evidence of criminal activity under the plain view doctrine, it is not necessary for sheriff's officers to obtain a warrant before entering a residence to seize the evidence." Bell, 737 P.2d at 259.