plain view doctrine (Michigan) · Go Syfert
← Michigan issues

plain view doctrine in Michigan

98 Michigan opinions name it 2 courts 1970–2026 16 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (27)

CaseFollowedCited
Coolidge v. New Hampshiregreen
scotus · 1971 · cited in 21 Michigan opinions naming this issue, 1973–2019
2 sentences

2006United States v Bishop, 338 F3d 623, 626-627 (CA 6, 2003) (stating that the plain view exception permits the warrantless seizure of objects dangerous in *308 themselves), citing Coolidge v New Hampshire, 403 US 443, 472 ; 91 S Ct 2022 ; 29 L Ed 2d 564 (1971) (plurality opinion).

2006United States v Bishop, 338 F3d 623, 626-627 (CA 6, 2003) (stating that the plain view exception permits the warrantless seizure of objects dangerous in *308 themselves), citing Coolidge v New Hampshire, 403 US 443, 472 ; 91 S Ct 2022 ; 29 L Ed 2d 564 (1971) (plurality opinion).

621
People v. Championgreen
mich · 1996 · cited in 36 Michigan opinions naming this issue, 1997–2026
2 sentences

2026“The plain view doctrine allows police officers to seize, without a warrant, items in plain view if the officers are lawfully in a position from which they view the item, and if the item’s incriminating character is immediately apparent.” People v Champion, 452 Mich 92, 101 ; 549 NW2d 849 (1996).

2026“The plain view doctrine allows police officers to seize, without a warrant, items in plain view if the officers are lawfully in a position from which they view the item, and if the item’s incriminating character is immediately apparent.” People v Champion, 452 Mich 92, 101 ; 549 NW2d 849 (1996).

336
Horton v. Californiagreen
scotus · 1990 · cited in 11 Michigan opinions naming this issue, 1990–2019
2 sentences

2017The seizure of an item pursuant to the plain view exception “is legitimate only where it is immediately apparent to the police that they have evidence before them; the ‘plain view’ doctrine may not be used to extend a general exploratory search from one object to another until something incriminating at last emerges.” Horton v California, 496 US 128, 136 ; 110 S Ct 2301, 2307 ; 110 L Ed 2d 112 (1990) (quotation marks and citation omitted).

2017The seizure of an item pursuant to the plain view exception “is legitimate only where it is immediately apparent to the police that they have evidence before them; the ‘plain view’ doctrine may not be used to extend a general exploratory search from one object to another until something incriminating at last emerges.” Horton v California, 496 US 128, 136 ; 110 S Ct 2301, 2307 ; 110 L Ed 2d 112 (1990) (quotation marks and citation omitted).

311
Minnesota v. Dickersongreen
scotus · 1993 · cited in 4 Michigan opinions naming this issue, 1996–2024
2 sentences

2024Under the plain-view doctrine, “if police are lawfully in a position from which they view an object, if its incriminating character is immediately apparent, and if the officers have a lawful right of access to the object, they may seize it without a warrant.” Minnesota v Dickerson, 508 US 366, 375 ; 113 S Ct 2130 ; 124 L Ed 2d 334 (1993); see also Champion, 452 Mich at 104 .

2024Under the plain-view doctrine, “if police are lawfully in a position from which they view an object, if its incriminating character is immediately apparent, and if the officers have a lawful right of access to the object, they may seize it without a warrant.” Minnesota v Dickerson, 508 US 366, 375 ; 113 S Ct 2130 ; 124 L Ed 2d 334 (1993); see also Champion, 452 Mich at 104 .

34
Arizona v. Hicksgreen
scotus · 1987 · cited in 7 Michigan opinions naming this issue, 1994–2011
2 sentences

2004The Supreme Court held that the plain view doctrine “ ‘may not be used to extend a general exploratory search from one object to another until something incriminating at last emerges.’ ” Id. at 328 , quoting Coolidge v New Hampshire, 403 US 443, 466 ; 91 S Ct 2022 ; 29 L Ed 2d 564 (1971).

2003Defendant, relying on Arizona v Hicks, 480 US 321 ; 107 S Ct 1149 ; 94 L Ed 2d 347 (1987), argues that the plain-view doctrine does not apply because the incriminating character of the vehicles was not immediately apparent and that the officer discovered incriminating information only after he began the search.

27
Harris v. United Statesgreen
scotus · 1968 · cited in 6 Michigan opinions naming this issue, 1973–1991
2 sentences

1982As the Supreme Court stated in Terry v Ohio, 392 US 1, 19, fn 16 ; 88 S Ct 1868 ; 20 L Ed 2d 889 (1968): "Only when the officer, by means of physical force or show of authority, has in some way restrained the liberty of a citizen may we conclude that a 'seizure’ has occurred.” 18 Harris v United States, 390 US 234, 236 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968). 19 None of the justices in Coolidge disputed this limitation. 403 US 490 (Harlan, J., concurring); p 492 (Burger, C.J., dissenting in part and concurring in part); p 493 (Black, J., concurring and dissenting); p 510 (White, J., concurring

1982As the Supreme Court stated in Terry v Ohio, 392 US 1, 19, fn 16 ; 88 S Ct 1868 ; 20 L Ed 2d 889 (1968): "Only when the officer, by means of physical force or show of authority, has in some way restrained the liberty of a citizen may we conclude that a 'seizure’ has occurred.” 18 Harris v United States, 390 US 234, 236 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968). 19 None of the justices in Coolidge disputed this limitation. 403 US 490 (Harlan, J., concurring); p 492 (Burger, C.J., dissenting in part and concurring in part); p 493 (Black, J., concurring and dissenting); p 510 (White, J., concurring

26
People v. Mahdigreen
michctapp · 2016 · cited in 5 Michigan opinions naming this issue, 2017–2021
2 sentences

2020“The plain view exception to the warrant requirement allows a police officer to seize items in plain view if the officer is lawfully in the position to have that view and the evidence is obviously incriminatory.” People v Mahdi, 317 Mich App 446, 462 ; 894 NW2d 732 (2016) (citation and quotation marks omitted).

2020“The plain view exception to the warrant requirement allows a police officer to seize items in plain view if the officer is lawfully in the position to have that view and the evidence is obviously incriminatory.” People v Mahdi, 317 Mich App 446, 462 ; 894 NW2d 732 (2016) (citation and quotation marks omitted).

25
People v. Gallowaygreen
michctapp · 2004 · cited in 11 Michigan opinions naming this issue, 2011–2019
2 sentences

2018In addition, under the plain-view exception, police officers may seize evidence “in plain view if the officer is lawfully in the position to have that view and the evidence is obviously incriminatory.” People v Galloway, 259 Mich App 634, 639 ; 675 NW2d 883 (2003).

2018In addition, under the plain-view exception, police officers may seize evidence “in plain view if the officer is lawfully in the position to have that view and the evidence is obviously incriminatory.” People v Galloway, 259 Mich App 634, 639 ; 675 NW2d 883 (2003).

111
Texas v. Browngreen
scotus · 1983 · cited in 5 Michigan opinions naming this issue, 1997–2023
2 sentences

2018If his vantage point was not within a constitutionally protected area, his observation using only his normal vision to see that which was open to public gaze, was permissible under the open view doctrine. [Citations and quotation marks omitted.] The Idaho court relied in part on Texas v. Brown , 460 U.S. 730 , 739, 103 S.Ct. 1535 , 75 L.Ed. 2d 502 (1983), wherein the United States Supreme Court indicated that the plain-view doctrine provides a basis to seize an item when the officer's access to the object had some previous justification under the Fourth Amendment.

2018If his vantage point was not within a constitutionally protected area, his observation using only his normal vision to see that which was open to public gaze, was permissible under the open view doctrine. [Citations and quotation marks omitted.] The Idaho court relied in part on Texas v. Brown , 460 U.S. 730 , 739, 103 S.Ct. 1535 , 75 L.Ed. 2d 502 (1983), wherein the United States Supreme Court indicated that the plain-view doctrine provides a basis to seize an item when the officer's access to the object had some previous justification under the Fourth Amendment.

15
Terry v. Ohiogreen
scotus · 1968 · cited in 4 Michigan opinions naming this issue, 1982–2025
2 sentences

2025To resolve this case, we must also consider whether the gun was found in plain view during an otherwise constitutional investigatory stop pursuant to Terry v Ohio, 392 US 1 ; 88 S Ct 1868 ; 20 L Ed 2d 889 (1968), and thus admissible under the plain-view exception to the warrant requirement.

2025To resolve this case, we must also consider whether the gun was found in plain view during an otherwise constitutional investigatory stop pursuant to Terry v Ohio, 392 US 1 ; 88 S Ct 1868 ; 20 L Ed 2d 889 (1968), and thus admissible under the plain-view exception to the warrant requirement.

14
People v. Trudeaugreen
mich · 1971 · cited in 3 Michigan opinions naming this issue, 1973–2024
2 sentences

2024Id. at 280 .

1973Upholding the seizure without a warrant in this case does not conflict with the decisions of the Michigan Supreme Court in Trudeau, supra, and Eddington, supra. The rationale of the Trudeau case for not applying the plain view doctrine to a seizure of shoes worn by an in-custody defendant was that there was no probable cause to seize the shoes, only a mere suspicion.

13
People v. Kuntzegreen
mich · 1963 · cited in 3 Michigan opinions naming this issue, 1973–1981
2 sentences

1981See, e.g., Whalen, supra, and Kuntze, supra. Therefore, the plain view doctrine applies to this case, and no "search” for Fourth Amendment purposes took place.

1973The plain view rule does not go into hibernation at sunset.” It does not appear to us now that our original holding in Kuntze, supra, was erroneous, or that the rule we espoused then has changed over the last ten years.

13
United States v. Galavizgreen
ca6 · 2011 · cited in 2 Michigan opinions naming this issue, 2024–2025
2 sentences

2025But the plain-view exception cannot apply to the officers’ seizure of the Escalade given the prosecution’s concession that the Escalade was parked in the curtilage of respondents’ home.3 3 This concession distinguishes this case from cases like United States v Galaviz, 645 F3d 347, 355-356 (CA 6, 2011), and United States v Coleman, 923 F3d 450, 455-457 (CA 6, 2019), where the Sixth Circuit held that vehicles parked in the driveways of homes were properly seized under the plain-view exception to the warrant requirement.

2024Galaviz, 645 F3d at 356 .

12
Katz v. United Statesgreen
scotus · 1967 · cited in 2 Michigan opinions naming this issue, 2002–2016
12
People v. Wilkensgreen
michctapp · 2005 · cited in 2 Michigan opinions naming this issue, 2011–2016
12
People v. Johnsongreen
michctapp · 1981 · cited in 2 Michigan opinions naming this issue, 1982–1982
12
People v. Hardengreen
michctapp · 1974 · cited in 2 Michigan opinions naming this issue, 1978–1978
12
Collins v. Virginiagreen
scotus · 2018 · cited in 1 Michigan opinions naming this issue, 2025–2025
11
United States v. Ronald Coleman, Jr.green
ca6 · 2019 · cited in 1 Michigan opinions naming this issue, 2025–2025
11
United States v. Gurczynskigreen
armfor · 2017 · cited in 1 Michigan opinions naming this issue, 2020–2020
11
United States v. Galpingreen
ca2 · 2013 · cited in 1 Michigan opinions naming this issue, 2020–2020
11
United States v. Williamsgreen
ca4 · 2010 · cited in 1 Michigan opinions naming this issue, 2020–2020
11
United States v. Sparksgreen
ca10 · 2002 · cited in 1 Michigan opinions naming this issue, 2017–2017
11
United States v. Wesley Dale Bishopgreen
ca6 · 2003 · cited in 1 Michigan opinions naming this issue, 2006–2006
11
United States v. Dunngreen
scotus · 1987 · cited in 1 Michigan opinions naming this issue, 2002–2002
11
People v. Bloydgreen
michctapp · 1980 · cited in 1 Michigan opinions naming this issue, 1986–1986
11
Warden, Maryland Penitentiary v. Haydengreen
scotus · 1967 · cited in 1 Michigan opinions naming this issue, 1980–1980
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (53)

CaseCitedYears
People v. Whalen green
mich · 1973
2 sentences

2002See United States v Dunn, 480 US 294, 305 ; 107 S Ct 1134 ; 94 L Ed 2d 326 (1987), and People v Whalen, 390 Mich 672, 678-679 ; 213 NW2d 116 (1973); see also Katz v United States, 389 US 347, 351 ; 88 S Ct 507 ; 19 L Ed 2d 576 (1967), and People v Champion, 452 Mich 92, 101-103 ; 549 NW2d 849 (1996) (discussing the plain view doctrine generally).

2002See United States v Dunn, 480 US 294, 305 ; 107 S Ct 1134 ; 94 L Ed 2d 326 (1987), and People v Whalen, 390 Mich 672, 678-679 ; 213 NW2d 116 (1973); see also Katz v United States, 389 US 347, 351 ; 88 S Ct 507 ; 19 L Ed 2d 576 (1967), and People v Champion, 452 Mich 92, 101-103 ; 549 NW2d 849 (1996) (discussing the plain view doctrine generally).

71975–2002
People v. Kazmierczak green
mich · 2000
2 sentences

2025Both the “Fourth Amendment of the United States Constitution and its counterpart in the Michigan Constitution guarantee the right of persons to be secure against unreasonable searches and seizures.” People v Kazmierczak, 461 Mich 411, 417 ; 605 NW2d 667 (2000).

2025Both the “Fourth Amendment of the United States Constitution and its counterpart in the Michigan Constitution guarantee the right of persons to be secure against unreasonable searches and seizures.” People v Kazmierczak, 461 Mich 411, 417 ; 605 NW2d 667 (2000).

42016–2025
People v. Cooke green
michctapp · 1992
2 sentences

2020“A seizure without a warrant may be valid under the plain-view exception to the warrant requirement where it is shown that (1) the incriminating character of the evidence was immediately apparent and (2) the police had a lawful right of access to the object.” People v Cooke, 194 Mich App 534, 536 ; 487 NW2d 497 (1992).

2020“A seizure without a warrant may be valid under the plain-view exception to the warrant requirement where it is shown that (1) the incriminating character of the evidence was immediately apparent and (2) the police had a lawful right of access to the object.” People v Cooke, 194 Mich App 534, 536 ; 487 NW2d 497 (1992).

41996–2020
People v. Tisi green
mich · 1970
2 sentences

1977United States v Lee, 274 US 559 ; 47 S Ct 746 ; 71 L Ed 1202 (1927).” The Supreme Court had previously adopted the following rule in People v Tisi, 384 Mich 214, 218 ; 180 NW2d 801 (1970): "In the recent case of Harris v United States, 390 US 234 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968), the Court said (p 236): " 'It has long been settled that objects falling in the *552 plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.’ ” Under the plain view doctrine, by which the instant seizure is justified, the most cru

1977United States v Lee, 274 US 559 ; 47 S Ct 746 ; 71 L Ed 1202 (1927).” The Supreme Court had previously adopted the following rule in People v Tisi, 384 Mich 214, 218 ; 180 NW2d 801 (1970): "In the recent case of Harris v United States, 390 US 234 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968), the Court said (p 236): " 'It has long been settled that objects falling in the *552 plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.’ ” Under the plain view doctrine, by which the instant seizure is justified, the most cru

41973–1991
People v. Johnson green
michctapp · 2011
2 sentences

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

32018–2018
People v. Minch green
mich · 2012
2 sentences

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

32018–2018
People v. Peals green
mich · 2006
2 sentences

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

32018–2018
People v. Bass green
michctapp · 2016
2 sentences

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

32018–2018
People v. Butler green
mich · 1982
2 sentences

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

2018And the officer’s observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer, 248 Mich App at 562 , thereby implicating, at this juncture, the plain view doctrine, Champion, 452 Mich at 101 , allowing for the seizure of the gun. 4 “Possession” is an element of felon-in-possession, MCL 750.224f; People v Bass, 317 Mich App 241, 268 ; 893 NW2d 140 (2016), and felony-firearm, MCL 750.227b; People v Peals, 476 Mich 636, 640 ; 720 NW2d 196 (2006); Johnson, 293 Mich App at 82-83 , and the “carrying” element of CCW has been equated to possessi

32018–2018
People v. Custer green
michctapp · 2002
2 sentences

2018And the officer's observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer , 248 Mich. App. at 562 , 640 N.W.2d 576 , thereby implicating, at this juncture, the plain-view doctrine, Champion , 452 Mich. at 101 , 549 N.W.2d 849 , allowing for the seizure of the gun.

2018And the officer's observation of the back of the gun handle was from a lawful position regardless of the use of the flashlight, Custer , 248 Mich. App. at 562 , 640 N.W.2d 576 , thereby implicating, at this juncture, the plain-view doctrine, Champion , 452 Mich. at 101 , 549 N.W.2d 849 , allowing for the seizure of the gun.

32018–2018
People v. Wilson green
michctapp · 2003
2 sentences

2017No searching, no matter how minimal, may be done under the auspices of the plain view doctrine.” People v Wilson, 257 Mich App 337, 361 ; 668 NW2d 371 (2003), vacated in part on other grounds 469 Mich 1018 (2004), quoting Champion, 452 Mich at 101.

2017No searching, no matter how minimal, may be done under the auspices of the plain view doctrine.” People v Wilson, 257 Mich App 337, 361 ; 668 NW2d 371 (2003), vacated in part on other grounds 469 Mich 1018 (2004), quoting Champion, 452 Mich at 101.

32004–2017
People v. Myshock green
michctapp · 1982
2 sentences

1991Coolidge v New Hampshire, 403 US 443, 466 ; 91 S Ct 2022 ; 29 L Ed 2d 564 (1971); People v Myshock, 116 Mich App 72, 75-76 ; 321 NW2d 849 (1982).

1991Coolidge v New Hampshire, 403 US 443, 466 ; 91 S Ct 2022 ; 29 L Ed 2d 564 (1971); People v Myshock, 116 Mich App 72, 75-76 ; 321 NW2d 849 (1982).

31985–1991
People v. Heard green
michctapp · 1975
2 sentences

1982People v Heard, 65 Mich App 494 ; 237 NW2d 525 (1975).

1982People v Heard, 65 Mich App 494 ; 237 NW2d 525 (1975).

31977–1982
United States v. Lee green
scotus · 1927
2 sentences

1977United States v Lee, 274 US 559 ; 47 S Ct 746 ; 71 L Ed 1202 (1927).” The Supreme Court had previously adopted the following rule in People v Tisi, 384 Mich 214, 218 ; 180 NW2d 801 (1970): "In the recent case of Harris v United States, 390 US 234 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968), the Court said (p 236): " 'It has long been settled that objects falling in the *552 plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.’ ” Under the plain view doctrine, by which the instant seizure is justified, the most cru

1977United States v Lee, 274 US 559 ; 47 S Ct 746 ; 71 L Ed 1202 (1927).” The Supreme Court had previously adopted the following rule in People v Tisi, 384 Mich 214, 218 ; 180 NW2d 801 (1970): "In the recent case of Harris v United States, 390 US 234 ; 88 S Ct 992 ; 19 L Ed 2d 1067 (1968), the Court said (p 236): " 'It has long been settled that objects falling in the *552 plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.’ ” Under the plain view doctrine, by which the instant seizure is justified, the most cru

31973–1977
People of Michigan v. Keenan Barbee green
michctapp · 2018
2 sentences

2025People v Barbee, 325 Mich App 1, 5-6 ; 923 NW2d 601 (2018).

2025People v Barbee, 325 Mich App 1, 5-6 ; 923 NW2d 601 (2018).

22023–2025
People v. Custer green
mich · 2001
2 sentences

2020However, “[t]he police cannot manipulate an object in order to determine whether it is contraband; it must be immediately apparent from plain view . . . that the object is contraband.” People v Custer, 465 Mich 319, 336 ; 630 NW2d 870 (2001).

2020However, “[t]he police cannot manipulate an object in order to determine whether it is contraband; it must be immediately apparent from plain view . . . that the object is contraband.” People v Custer, 465 Mich 319, 336 ; 630 NW2d 870 (2001).

22004–2020
People v. Brzezinski green
michctapp · 2001
2 sentences

2017From the tree line, Henderson observed an “overwhelming” and “extensive” amount of smoke coming from the chimney that smelled like an “extremely excess amount of freshly burned marijuana,” and he could see the living room “getting brighter and brighter” “from a fire.” Based on this information, Henderson and Keller clearly had probable cause, Brzezinski, 243 Mich App at 433 -434 and the issue we are faced with is whether the requisites for application of the plain view exception existed.

2017From the tree line, Henderson observed an “overwhelming” and “extensive” amount of smoke coming from the chimney that smelled like an “extremely excess amount of freshly burned marijuana,” and he could see the living room “getting brighter and brighter” “from a fire.” Based on this information, Henderson and Keller clearly had probable cause, Brzezinski, 243 Mich App at 433 -434 and the issue we are faced with is whether the requisites for application of the plain view exception existed.

22017–2017
People v. Goodman green
michctapp · 1975
21981–2002
People v. Alfafara green
michctapp · 1985
21986–1991
People v. Dugan green
michctapp · 1980
21982–1985
People v. Murphy green
michctapp · 1978
21980–1982
People v. Brown green
michctapp · 2008
12025–2025
United States v. Anthony Williams green
ca6 · 2012
12024–2024
People v. Henderson green
mich · 1974
12024–2024
People v. Edwards green
michctapp · 1977
12024–2024
Mapp v. Ohio green
scotus · 1961
12020–2020
People v. Unger green
michctapp · 2008
12019–2019
United States v. Knights green
scotus · 2001
12016–2016
People v. Collins green
michctapp · 2012
12015–2015
People v. Seals green
michctapp · 2009
12015–2015
People v. Vaughn green
mich · 2012
12015–2015
Smith v. ANONYMOUS JOINT ENTERPRISE green
mich · 2010
12015–2015
People v. Waclawski green
michctapp · 2009
12015–2015
United States v. Mark Edwin Sells green
ca10 · 2006
12007–2007
People v. Oliver green
mich · 1983
12004–2004
People v. Raybon green
michctapp · 1983
12004–2004
People v. Frohriep green
michctapp · 2001
12004–2004
Michigan v. Long green
scotus · 1983
11996–1996
People v. Davis neutral
michctapp · 1991
11992–1992
People v. Blackburne green
michctapp · 1986
11992–1992

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 750.227b (29) MI § Mich. Comp. Laws § 750.224f (22) MI § Mich. Comp. Laws § 333.7403 (18) MI § Mich. Comp. Laws § 750.227 (18) MI § Mich. Comp. Laws § 333.7401 (17) MI § Mich. Comp. Laws § 769.12 (11) MI § Mich. Comp. Laws § 750.316 (8) MI § Mich. Comp. Laws § 750.529 (7) MI § Mich. Comp. Laws § 750.535 (6) MI § Mich. Comp. Laws § 764.15 (6) MI § Mich. Comp. Laws § 750.157a (5) MI § Mich. Comp. Laws § 750.110 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 323 (1973–2026) PA 276 (1970–2026) TX 266 (1972–2026) LA 207 (1975–2025) NJ 156 (1977–2026) IL 148 (1968–2025) NY 138 (1972–2026) WA 118 (1971–2026) GA 98 (1974–2024) MI 98 (1970–2026) IN 96 (1971–2023) VA 82 (1987–2026) FL 80 (1973–2026) MA 76 (1975–2026) CA 74 (1972–2026) MO 73 (1972–2017) TN 69 (1980–2025) NC 63 (1974–2025) CT 59 (1973–2025) AL 59 (1971–2018) CO 59 (1970–2026) KS 54 (1971–2022) MD 51 (1972–2026) OR 45 (1972–2026) MN 44 (1977–2024) ID 43 (1974–2026) NM 43 (1975–2025) WI 41 (1973–2025) MS 37 (1977–2025) DC 32 (1973–2025) MT 31 (1977–2025) IA 31 (1976–2026) SC 29 (1983–2023) KY 28 (1972–2025) AR 27 (1977–2021) OK 26 (1977–2015) ND 23 (1981–2026) AZ 22 (1973–2022) NE 21 (1976–2022) UT 19 (1981–2006) NH 19 (1976–2019) WY 18 (1979–2019) HI 17 (1975–2021) DE 17 (1971–2025) WV 17 (1980–2023) RI 16 (1974–2010) ME 16 (1971–2025) AK 16 (1974–2019) NV 15 (1981–2021) VT 12 (1976–2021) SD 11 (1973–2006) VI 8 (1984–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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