The U.S. Supreme Court in Michigan v. Clifford (1984) held that if the primary object of a search is to determine the cause and origin of a fire, an administrative warrant will suffice, and if the primary object is to gather evidence of criminal activity, a criminal search warrant may be obtained only on a showing of probable cause to believe that relevant evidence will be found in the place to be searched. Fourth amendment limitations on searches and seizures, however, apply only to governmental activities and not to the acts of private persons. Private security persons who work with an official investigator are bound by limitations on government investigators. This means the investigation should begin as soon as possible, even during firefighting operations. Evidence viewed or seized during these operations is admissible under the "plain view" doctrine. The building or area should be secured as soon as possible to preclude the defense from arguing that evidence was tampered with, removed, or added. Every effort should be made to conduct a continuous investigation once started without leaving the area or building. A warrant is not required as long as an emergency exists, and any evidence discovered should be admissible. Evidence taken with the permission of the owner of the premises is admissible, but a warrant is not necessary if the owner abandoned the property. An administrative warrant cannot be used after evidence of arson is detected. A criminal warrant must be obtained to continue the search once arson is suspected.