State v. Grant

GUILT-PHASE ISSUES

In Grant’s first proposition of law, she argues that all visits to her house by police and fire officials on April 1, 5 and 14 were warrantless and, except for the initial fire-fighting efforts, unlawful. The state concedes that the April 5 search was unlawful. Nonetheless, under the circumstances, Chief Cover’s testimony based on that search was cumulative and thus its admission was harmless error.

Exigent circumstances justified the warrantless search on April 1. In Michigan v. Tyler (1978), 436 U.S. 499, 510, 98 S.Ct. 1942, 1950, 56 L.Ed.2d 486, 498, the United States…