inevitable discovery doctrine (Kansas) · Go Syfert
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inevitable discovery doctrine in Kansas

29 Kansas opinions name it 2 courts 1989–2022 3 in the last five years

The cases below were cited by Kansas 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 (12)

CaseFollowedCited
State v. Godfreygreen
kan · 2015 · cited in 2 Kansas opinions naming this issue, 2019–2019
2 sentences

2019See State v. Godfrey , 301 Kan. 1041 , 1044, 350 P.3d 1068 (2015) ( Rule 6.02 [a][5] is to be strictly enforced).

2019See State v. Godfrey , 301 Kan. 1041 , 1044, 350 P.3d 1068 (2015) ( Rule 6.02 [a][5] is to be strictly enforced).

22
Nix v. Williamsgreen
scotus · 1984 · cited in 7 Kansas opinions naming this issue, 1989–2013
2 sentences

1990The inevitable discovery doctrine was set out in Nix v. Williams, 467 U.S. 431, 444 , 81 L.

1990The inevitable discovery doctrine was set out in Nix v. Williams, 467 U.S. 431, 444 , 81 L.

17
State v. Huffgreen
kan · 2004 · cited in 4 Kansas opinions naming this issue, 2006–2018
2 sentences

2011“Under the inevitable discovery doctrine, evidence will not be suppressed, despite a constitutional violation in the way it was discovered or obtained, if the same evidence could have come to the attention of law enforcement independent of the violation. [Citation omitted.]” State v. Huff, 278 Kan. 214, 221 , 92 P.3d 604 (2004).

2011“Under the inevitable discovery doctrine, evidence will not be suppressed, despite a constitutional violation in the way it was discovered or obtained, if the same evidence could have come to the attention of law enforcement independent of the violation. [Citation omitted.]” State v. Huff, 278 Kan. 214, 221 , 92 P.3d 604 (2004).

14
State v. Ackwardgreen
kan · 2006 · cited in 3 Kansas opinions naming this issue, 2007–2018
2 sentences

2007App. 2d 129 , Syl. ¶ 4, 784 P.2d 381 (1989): “Evidence obtained unlawfully in violation of a defendant’s constitutional rights is admissible under the inevitable discovery exception to the exclusionary rule where the prosecution can prove by a preponderance of the evidence that the unlawfully obtained evidence would have ultimately or inevitably been discovered by lawful means.” Accord State v. Ackward, 281 Kan. 2, 18 , 128 P.3d 382 (2006).

2007App. 2d 129 , Syl. ¶ 4, 784 P.2d 381 (1989): “Evidence obtained unlawfully in violation of a defendant’s constitutional rights is admissible under the inevitable discovery exception to the exclusionary rule where the prosecution can prove by a preponderance of the evidence that the unlawfully obtained evidence would have ultimately or inevitably been discovered by lawful means.” Accord State v. Ackward, 281 Kan. 2, 18 , 128 P.3d 382 (2006).

13
Utah v. Strieffgreen
scotus · 2016 · cited in 3 Kansas opinions naming this issue, 2017–2018
2 sentences

2018Another exception, at issue here, is the attenuation doctrine. 136 S.Ct. at 2061 .

2017One exception to the exclusionary rule is the inevitable discovery doctrine, which "allows for the admission of evidence that would have been discovered even without the unconstitutional source," Utah v. Strieff, 579 U.S. __ , 136 S. Ct. 2056, 2059 , 195 L.

13
State v. Ingramgreen
kan · 2005 · cited in 3 Kansas opinions naming this issue, 2006–2011
2 sentences

2011“The test under the inevitable discovery rule is that, if the prosecution establishes by a preponderance of the evidence that the unlawfully obtained evidence ultimately or inevitably would have been discovered by lawful means, the evidence is admissible.” State v. Ingram, 279 Kan. 745, 750 , 113 P.3d 228 (2005).

2011“The test under the inevitable discovery rule is that, if the prosecution establishes by a preponderance of the evidence that the unlawfully obtained evidence ultimately or inevitably would have been discovered by lawful means, the evidence is admissible.” State v. Ingram, 279 Kan. 745, 750 , 113 P.3d 228 (2005).

13
Utah v. Strieffgreen
scotus · 2016 · cited in 2 Kansas opinions naming this issue, 2017–2017
2 sentences

2017One exception to the exclusionary rule is the inevitable discovery doctrine, which "allows for the admission of evidence that would have been discovered even without the unconstitutional source," Utah v. Strieff, 579 U.S. __ , 136 S. Ct. 2056, 2059 , 195 L.

2017See Utah v. Strieff, 579 U.S. ___ , 136 S. Ct. 2056, 2061 , 195 L.

12
State v. Browngreen
kan · 1989 · cited in 2 Kansas opinions naming this issue, 2000–2005
2 sentences

2005State v. Brown, 245 Kan. 604, 612 , 783 P.2d 1278 (1989) (citing Nix v. Williams, 467 U.S. 431, 444 , 81 L.

2005State v. Brown, 245 Kan. 604, 612 , 783 P.2d 1278 (1989) (citing Nix v. Williams, 467 U.S. 431, 444 , 81 L.

12
State v. Kellygreen
kan · 2014 · cited in 1 Kansas opinions naming this issue, 2021–2021
2 sentences

2021See State v. Kelly, 298 Kan. 965, 971 , 318 P.3d 987 (2014).

2021See State v. Kelly, 298 Kan. 965, 971 , 318 P.3d 987 (2014).

11
State v. Canaangreen
kan · 1998 · cited in 1 Kansas opinions naming this issue, 2004–2004
2 sentences

2004See State v. Canaan, 265 Kan. 835 , 964 P.2d 681 (1998).

2004See State v. Canaan, 265 Kan. 835 , 964 P.2d 681 (1998).

11
State v. McKessorgreen
kan · 1990 · cited in 1 Kansas opinions naming this issue, 1993–1993
2 sentences

1993See State v. McKessor, 246 Kan. 1, 7-8 , 785 P.2d 1332 , cert, denied 495 U.S. 937 (1990).

1993See State v. McKessor, 246 Kan. 1, 7-8 , 785 P.2d 1332 , cert, denied 495 U.S. 937 (1990).

11
Lawrence v. Texas Employment Commissiongreen
scotus · 1990 · cited in 1 Kansas opinions naming this issue, 1993–1993
1 sentence

1993See State v. McKessor, 246 Kan. 1, 7-8 , 785 P.2d 1332 , cert, denied 495 U.S. 937 (1990).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (9)

CaseCitedYears
State v. Waddell green
kanctapp · 1989
2 sentences

2007“Evidence obtained unlawfully in violation of a defendant’s constitutional rights is admissible under the inevitable discovery exception to the exclusionary rule where the prosecution can prove by a preponderance of the evidence that the unlawfully obtained evidence would have ultimately or inevitably been dis *126 covered by lawful means.” State v. Waddell, 14 Kan.

2007App. 2d 129 , Syl. ¶ 4, 784 P.2d 381 (1989): “Evidence obtained unlawfully in violation of a defendant’s constitutional rights is admissible under the inevitable discovery exception to the exclusionary rule where the prosecution can prove by a preponderance of the evidence that the unlawfully obtained evidence would have ultimately or inevitably been discovered by lawful means.” Accord State v. Ackward, 281 Kan. 2, 18 , 128 P.3d 382 (2006).

41999–2007
State v. Alvarez green
kan · 2019
2 sentences

2019"Generally, parties may not raise constitutional issues for the first time on appeal unless they successfully argue that one of three recognized exceptions applies." State v. Alvarez , 309 Kan. 203 , 209, 432 P.3d 1015 (2019).

2019"Generally, parties may not raise constitutional issues for the first time on appeal unless they successfully argue that one of three recognized exceptions applies." State v. Alvarez , 309 Kan. 203 , 209, 432 P.3d 1015 (2019).

22019–2019
State v. Sanchez-Loredo green
kan · 2012
2 sentences

2022See, e.g., Baker, 306 Kan. at 592-94 (finding that the State's failure to provide any evidence of a policy or routine regarding opening containers during inventory searches was fatal to the State's inevitable discovery claim); State v. Fitzgerald, 286 Kan. 1124, 1132-33 , 192 P.3d 171 (2008) abrogated on other grounds by State v. Sanchez-Loredo, 294 Kan. 50 , 272 P.3d 34 (2012) (finding that when the State fails to put on evidence to meet its burden of proving inevitability, the inevitable discovery doctrine does not apply).

2022See, e.g., Baker, 306 Kan. at 592-94 (finding that the State's failure to provide any evidence of a policy or routine regarding opening containers during inventory searches was fatal to the State's inevitable discovery claim); State v. Fitzgerald, 286 Kan. 1124, 1132-33 , 192 P.3d 171 (2008) abrogated on other grounds by State v. Sanchez-Loredo, 294 Kan. 50 , 272 P.3d 34 (2012) (finding that when the State fails to put on evidence to meet its burden of proving inevitability, the inevitable discovery doctrine does not apply).

12022–2022
State v. Hanke green
kan · 2018
1 sentence

2022State v. Hanke, 307 Kan. 823 , 827, 415 P.3d 966 (2018). 15 The State argued, and the district court agreed, that although the officers conducted an illegal, warrantless search of Campbell's car, the inevitable discovery exception to the exclusionary rule saved the fruits of the illegal search.

12022–2022
State v. Fitzgerald green
kan · 2008
2 sentences

2022See, e.g., Baker, 306 Kan. at 592-94 (finding that the State's failure to provide any evidence of a policy or routine regarding opening containers during inventory searches was fatal to the State's inevitable discovery claim); State v. Fitzgerald, 286 Kan. 1124, 1132-33 , 192 P.3d 171 (2008) abrogated on other grounds by State v. Sanchez-Loredo, 294 Kan. 50 , 272 P.3d 34 (2012) (finding that when the State fails to put on evidence to meet its burden of proving inevitability, the inevitable discovery doctrine does not apply).

2022See, e.g., Baker, 306 Kan. at 592-94 (finding that the State's failure to provide any evidence of a policy or routine regarding opening containers during inventory searches was fatal to the State's inevitable discovery claim); State v. Fitzgerald, 286 Kan. 1124, 1132-33 , 192 P.3d 171 (2008) abrogated on other grounds by State v. Sanchez-Loredo, 294 Kan. 50 , 272 P.3d 34 (2012) (finding that when the State fails to put on evidence to meet its burden of proving inevitability, the inevitable discovery doctrine does not apply).

12022–2022
State v. Hubbard green
kan · 2018
1 sentence

2022When an "affidavit contains both lawfully and unlawfully obtained information, the court asks whether the affidavit supplied a substantial basis for finding probable cause absent the unlawfully obtained information." State v. Hubbard, 309 Kan. 22 , 33, 430 P.3d 956 (2018).

12022–2022
Illinois v. Lafayette green
scotus · 1983
1 sentence

2017The failure to present any evidence of standardized criteria or an established routine governing the opening of closed containers during inventory searches is fatal to the State's inevitable discovery claim. "[I]t is not 'unreasonable' for police, as part of the routine procedure incident to incarcerating an arrested person, to search any container or article in his possession, in 10 accordance with established inventory procedures." Lafayette, 462 U.S. at 648 .

12017–2017
State v. Conn green
kan · 2004
2 sentences

2006We believe the district court’s decision that McDonald controls is supported by State v. Conn, 278 Kan. 387, 395 , 99 P.3d 1108 (2004) (quoting State ex rel.

2006We believe the district court’s decision that McDonald controls is supported by State v. Conn, 278 Kan. 387, 395 , 99 P.3d 1108 (2004) (quoting State ex rel.

12006–2006
Murray v. United States green
scotus · 1988
2 sentences

1989In Murray v. United States, 487 U.S. 533 , 101 L.

1989In Murray v. United States, 487 U.S. 533 , 101 L.

11989–1989

Statutes the citing opinions construe

KS § K.S.A. § 20-3018 (5) KS § K.S.A. § 22-2402 (5) KS § K.S.A. § 65-4160 (5) KS § K.S.A. § 22-2401 (4) KS § K.S.A. § 22-2501 (4) KS § K.S.A. § 22-3216 (3)

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

PA 125 (1985–2026) OH 111 (1984–2026) CA 101 (1978–2026) NJ 85 (1979–2026) FL 75 (1983–2025) IL 74 (1980–2026) NY 67 (1975–2024) LA 62 (1984–2025) WA 60 (1982–2024) TX 58 (1981–2025) VA 51 (1986–2026) MI 48 (1978–2026) OR 45 (1976–2025) MA 42 (1985–2025) GA 40 (1999–2025) CT 37 (1986–2021) AZ 35 (1978–2025) ID 33 (1984–2026) NM 32 (1980–2023) KS 29 (1989–2022) WI 28 (1988–2026) MO 28 (1984–2025) TN 28 (1983–2026) NC 25 (1992–2024) IN 25 (1988–2018) MD 25 (1980–2025) ND 24 (1980–2023) MN 23 (1980–2024) CO 22 (1983–2025) IA 21 (1979–2025) DE 20 (1981–2026) UT 20 (1991–2025) AL 18 (1986–2026) DC 18 (1978–2025) ME 17 (1980–2025) NE 16 (1984–2024) SC 15 (2006–2024) MT 13 (2000–2020) AK 11 (1982–2008) WV 11 (2002–2024) SD 10 (1984–2024) KY 9 (2002–2024) HI 9 (1995–2023) NV 6 (1982–2024) NH 6 (1979–2021) OK 6 (1994–2023) MS 6 (2002–2026) AR 5 (1988–2019) RI 4 (2004–2024) VT 2 (2007–2007) WY 2 (2003–2022)

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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