The U.S. Supreme Court case Michigan v. Tyler et al., 1977, revolved around the question of whether fire investigators violated the Fourth Amendment rights of a business owner by returning to his burned premises multiple times without a warrant for further investigation and evidence collection. The court ruled that while initial entry immediately following the fire was legal due to exigent circumstances, subsequent entries required a search warrant as they were not immediate investigations or emergencies. However, items in plain view during these visits could be seized under the "plain view" doctrine if their incriminating nature was immediately apparent. This ruling clarified how Fourth Amendment protections apply in situations where public safety officials need to investigate potentially criminal causes of fires.

In the dissenting opinion for Michigan v. Tyler, Justice William Rehnquist argued that the majority's decision was too broad and failed to take into account practical considerations of fire investigations. He contended that a burning building does not suddenly become a constitutionally protected area once flames are extinguished, especially when it is necessary for investigators to determine cause and origin of the fire or if arson occurred. The justice also disagreed with the majority's view on what constitutes an "emergency" situation; he believed this should extend beyond just active fires to include subsequent investigations as well. Furthermore, he criticized their requirement for warrants in these situations as impractical due to unpredictable nature of fires and potential delays in obtaining such permissions which could hinder crucial investigative work.