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

28 Wisconsin opinions name it 2 courts 1988–2026 10 in the last five years

The cases below were cited by Wisconsin 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 (40)

CaseFollowedCited
Nix v. Williamsgreen
scotus · 1984 · cited in 9 Wisconsin opinions naming this issue, 1991–2024
2 sentences

2024See State v. Jackson, 2016 WI 56, ¶46 , 369 Wis. 2d 673 , 882 N.W.2d 422 . ¶9 In Nix v. Williams, 467 U.S. 431 (1984), the United States Supreme Court held that the inevitable discovery doctrine is an exception to the exclusionary rule.

2021In the State’s view, the existence of the search warrant authorizing police to confiscate the iPhone made the seizure of the device inevitable under the facts here. ¶9 Articulated in Nix v. Williams, 467 U.S. 431 (1984), the inevitable discovery doctrine provides as follows: “If the prosecution can establish by a preponderance of the evidence that the information ultimately or inevitably would have been discovered by lawful means … then the deterrence rationale [for police misconduct] has so little basis that the evidence should be received.” Id. at 444 .

69
State v. Mastella L. Jacksongreen
wis · 2016 · cited in 9 Wisconsin opinions naming this issue, 2017–2025
2 sentences

2025“Under the inevitable discovery doctrine, ‘evidence obtained during a search which is tainted by some illegal act may be admissible if the tainted evidence would have been inevitably discovered by lawful means.’” State v. Jackson, 2016 WI 56, ¶47 , 369 Wis. 2d 673 , 882 N.W.2d 422 (quoted source omitted). “[T]he State has the burden of proof in satisfying this narrow exception to the exclusionary rule.” Id., ¶72. ¶35 Here, as noted above, the circuit court concluded that the inevitable discovery doctrine applied either because Meloy would have voluntarily exited his garage or because the offic

2025“Under the inevitable discovery doctrine, ‘evidence obtained during a search which is tainted by some illegal act may be admissible if the tainted evidence would have been inevitably discovered by lawful means.’” State v. Jackson, 2016 WI 56, ¶47 , 369 Wis. 2d 673 , 882 N.W.2d 422 (quoted source omitted). “[T]he State has the burden of proof in satisfying this narrow exception to the exclusionary rule.” Id., ¶72. ¶35 Here, as noted above, the circuit court concluded that the inevitable discovery doctrine applied either because Meloy would have voluntarily exited his garage or because the offic

59
United States v. James Thomas Cherrygreen
ca5 · 1985 · cited in 4 Wisconsin opinions naming this issue, 2003–2016
2 sentences

2016To a degree, the Cherry court anticipated this critique by acknowledging a case in which, despite the fact that "the Brookins prerequisites were not met," the Fifth Circuit "held that the inevitable discovery exception applied since the alternate means for obtaining the evidence was an intervening and independent event occurring subsequent to the misconduct." Cherry, 759 F.2d at 1205 (citing United States v. Miller, 666 F.2d 991, 997 (5th Cir. 1982)).

2009See United States v. Cherry, 759 F.2d 1196, 1205-06 (5th Cir. 1985) (explaining that application of the inevitable discovery doctrine, where agents "could have obtained a warrant but had made no effort to do so," undercuts the warrant requirement). ¶ 50.

34
Murray v. United Statesgreen
scotus · 1988 · cited in 3 Wisconsin opinions naming this issue, 2014–2021
2 sentences

2016Under the inevitable discovery doctrine, which was not developed by the State, illegally obtained evidence is admissible if the state can show that it" 'inevitably would have been discovered by lawful means.'" State v. Anker, 2014 WI App 107, ¶ 25 , 357 Wis. 2d 565 , 855 N.W.2d 483 (quoting State v. Schwegler, 170 Wis. 2d 487, 499 , 490 N.W.2d 292 (Ct. App. 1992) (emphasis added); see Murray v. United States, 487 U.S. 533, 539 (1988).

2014See Murray v. United States, 487 U.S. 533, 539 (1988) ("The inevitable discovery doctrine, with its distinct requirements, is in reality an extrapolation from the independent source doctrine.").

33
Smith v. Stategreen
alaska · 1997 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). ¶ 140.

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). 43 Knapp, 2

22
Commonwealth v. Sbordonegreen
mass · 1997 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). ¶ 140.

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). 43 Knapp, 2

22
State v. Averygreen
wisctapp · 2011 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016See State v. Avery, 2011 WI App 124 , 337 Wis. 2d 351 , 804 N.W.2d 216 ; State v. Lopez, 207 Wis. 2d 413 , 559 N.W.2d 264 2 No. 2014AP2238-CR (Ct. App. 1996); State v. Schwegler, 170 Wis. 2d 487 , 490 N.W.2d 292 (Ct. App. 1992). ¶5 Jackson now urges us to reassess the inevitable discovery doctrine.

2016See State v. Avery, 2011 WI App 124 , 337 Wis. 2d 351 , 804 N.W.2d 216 ; State v. Lopez, 207 Wis. 2d 413 , 559 N.W.2d 264 2 No. 2014AP2238-CR (Ct. App. 1996); State v. Schwegler, 170 Wis. 2d 487 , 490 N.W.2d 292 (Ct. App. 1992). ¶5 Jackson now urges us to reassess the inevitable discovery doctrine.

22
State v. Hollygreen
nd · 2013 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). ¶ 140.

2016See, e.g., Commonwealth v. Mattier, 50 N.E.3d 157, 167 (Mass. 2016) (citing Commonwealth v. Sbordone, 678 N.E.2d 1184, 1190 (Mass. 1997)); State v. Holly, 833 N.W.2d 15, 33 (N.D. 2013) (citing State v. Phelps, 297 N.W.2d 769, 775 (N.D. 1980)); Smith v. State, 948 P.2d 473, 481 (Alaska 1997); see also United States v. Madrid, 152 F.3d 1034, 1041 (8th Cir. 1998) (declaring that courts are not required to apply the inevitable discovery doctrine "without regard to the severity of the police misconduct"); but see State v. Garner, 417 S.E.2d 502, 510-11 (N.C. 1992) (rejecting this view). 43 Knapp, 2

22
State v. Schweglergreen
wisctapp · 1992 · cited in 6 Wisconsin opinions naming this issue, 2003–2016
2 sentences

2016Under the inevitable discovery doctrine, which was not developed by the State, illegally obtained evidence is admissible if the state can show that it" 'inevitably would have been discovered by lawful means.'" State v. Anker, 2014 WI App 107, ¶ 25 , 357 Wis. 2d 565 , 855 N.W.2d 483 (quoting State v. Schwegler, 170 Wis. 2d 487, 499 , 490 N.W.2d 292 (Ct. App. 1992) (emphasis added); see Murray v. United States, 487 U.S. 533, 539 (1988).

2016Under the inevitable discovery doctrine, which was not developed by the State, illegally obtained evidence is admissible if the state can show that it" 'inevitably would have been discovered by lawful means.'" State v. Anker, 2014 WI App 107, ¶ 25 , 357 Wis. 2d 565 , 855 N.W.2d 483 (quoting State v. Schwegler, 170 Wis. 2d 487, 499 , 490 N.W.2d 292 (Ct. App. 1992) (emphasis added); see Murray v. United States, 487 U.S. 533, 539 (1988).

16
State v. Lopezgreen
wisctapp · 1996 · cited in 4 Wisconsin opinions naming this issue, 2005–2016
2 sentences

2016Under the inevitable discovery doctrine, "evidence obtained during a search which is tainted by some illegal act may be admissible if the tainted evidence would have been inevitably discovered by lawful means." State v. Lopez, 207 Wis. 2d 413, 427 , 559 N.W.2d 264 (Ct. App. 1996) (citing State v. Schwegler, 170 Wis. 2d 487, 499 , 490 N.W.2d 292 (Ct. App. 1992)); see also 6 Wayne R.

2016Under the inevitable discovery doctrine, "evidence obtained during a search which is tainted by some illegal act may be admissible if the tainted evidence would have been inevitably discovered by lawful means." State v. Lopez, 207 Wis. 2d 413, 427 , 559 N.W.2d 264 (Ct. App. 1996) (citing State v. Schwegler, 170 Wis. 2d 487, 499 , 490 N.W.2d 292 (Ct. App. 1992)); see also 6 Wayne R.

14
State v. Knappgreen
wis · 2005 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016When such transgressions are acknowledged yet forgiven by the courts, we endorse and invite their repetition." United States v. Olsen, 737 F.3d 625, 632 (9th Cir. 2013) (Kozinski, C.J., joined by four judges, dissenting from denial of rehearing en banc); see also Knapp, 285 Wis. 2d 86, ¶¶75, 79 . 18 See ¶134, infra (quoting Professor LaFave's criticism of a court's using the inevitable discovery doctrine under these circumstances). 6 No. 2014AP2238-CR.ssa Rather, the State challenges only the suppression of the physical evidence seized at Jackson's home. ¶113 The majority opinion agrees with t

2016In concluding that suppression of the physical evidence is necessary, I adhere to the reasoning in State v. Knapp, 2005 WI 127 , 285 Wis. 2d 86 , 700 N.W.2d 899 , which held that physical evidence obtained as a direct result of an intentional violation of Miranda is inadmissible under Article I, Section 8 of the Wisconsin Constitution. ¶116 In refusing to suppress the physical evidence obtained at Jackson's home, the majority opinion applies the inevitable discovery doctrine, an exception to the exclusionary rule.20 I disagree with applying the inevitable discovery doctrine in the instant case

12
United States v. Jason Guidrygreen
ca7 · 2016 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
1 sentence

2024For example, in United States v. Guidry, 817 F.3d 997, 1001 (7th Cir. 2016), police lawfully stopped a driver, Guidry, for a traffic offense.

11
State v. Quigleygreen
wisctapp · 2016 · cited in 1 Wisconsin opinions naming this issue, 2022–2022
1 sentence

2022The independent source doctrine does not apply, but the inevitable discovery doctrine does apply and provides a basis for us to affirm. ¶23 To explain, “the independent source doctrine requires proof that the tainted evidence was actually discovered by independent and lawful means; that is, it was ‘obtained independently from activities untainted by the initial illegality.’” Quigley, 370 Wis. 2d 702, ¶51 (citation omitted).

11
Utah v. Strieffgreen
scotus · 2016 · cited in 1 Wisconsin opinions naming this issue, 2022–2022
2 sentences

2022See Utah v. Strieff, 579 U.S. 232, 238 (2016).

2022This leaves the attenuation doctrine. ¶35 The attenuation doctrine provides that “[e]vidence is admissible when the connection between unconstitutional police conduct and the evidence is remote or has been interrupted by some intervening circumstance, so that ‘the interest protected by the constitutional guarantee that has been violated would not be served by suppression of the evidence obtained.’” Id. (citation omitted).

11
Bailey v. United Statesgreen
scotus · 2013 · cited in 1 Wisconsin opinions naming this issue, 2021–2021
2 sentences

2021He now appeals the denial of his suppression motion.2 1 In response to a subsequent recusal motion, the circuit court provided further explanation of its thinking regarding the potential applicability of Bailey v. United States, 568 U.S. 186 (2013), including by remarking that it was relying on defense counsel’s representation of that case and opining that the search of Walentowski’s iPhone involved a “clearcut” application of the inevitable discovery doctrine. 2 See WIS.

2021See Ybarra v. Illinois, 444 U.S. 85, 91 (1979) (“Where the standard is probable cause, a search or seizure of a person must be supported by probable cause particularized with respect to that person.”); see also Bailey, 568 U.S. at 196 (“If Bailey had rushed back to his apartment, the police could have apprehended and detained him under Summers.”). ¶13 Walentowski responds that the notion he would have returned home is speculative and cannot form the basis for application of the inevitable discovery doctrine.

11
Ybarra v. Illinoisgreen
scotus · 1980 · cited in 1 Wisconsin opinions naming this issue, 2021–2021
1 sentence

2021See Ybarra v. Illinois, 444 U.S. 85, 91 (1979) (“Where the standard is probable cause, a search or seizure of a person must be supported by probable cause particularized with respect to that person.”); see also Bailey, 568 U.S. at 196 (“If Bailey had rushed back to his apartment, the police could have apprehended and detained him under Summers.”). ¶13 Walentowski responds that the notion he would have returned home is speculative and cannot form the basis for application of the inevitable discovery doctrine.

11
United States v. Timothy W. Marklinggreen
ca7 · 1993 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
State v. Phelpsgreen
nd · 1980 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
Olmstead v. United Statesred
scotus · 1928 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Clifford Jerome Miller, United States of America v. Kathelyn Vandraiss Miller, United States of America v. Clifford Jerome Millergreen
ca5 · 1982 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. James Morrow Roper, Christian Matthew Newton, John Jackson Miller Truxellgreen
ca11 · 1982 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Frederick Silvestri, Eldergreen
ca1 · 1986 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Rickie Lee Boatwrightgreen
ca9 · 1987 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
Souza v. Commonwealthgreen
mass · 2015 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Larry Duane Conner, United States of America v. John Charles Tiltongreen
ca8 · 1997 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Thomasgreen
ca8 · 2008 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Rene Madridgreen
ca8 · 1998 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Marroccogreen
ca7 · 2009 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Kenneth Olsengreen
ca9 · 2013 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Howardgreen
ca7 · 2013 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11
United States v. Alexandergreen
ca6 · 2008 · cited in 1 Wisconsin opinions naming this issue, 2015–2015
11
State v. Caingreen
wis · 2012 · cited in 1 Wisconsin opinions naming this issue, 2013–2013
11
Cruzan Ex Rel. Cruzan v. Director, Missouri Department of Healthgreen
scotus · 1990 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
11
State v. Stronggreen
iowa · 1992 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
11
Ker v. Californiagreen
scotus · 1963 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
11
State v. Romegreen
wisctapp · 2000 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
11
State v. Jonesgreen
wis · 1995 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
11
McNeil v. Wisconsingreen
scotus · 1991 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
11
Michigan v. Harveygreen
scotus · 1990 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
11
Thompson v. Village of Hales Cornersgreen
wis · 1983 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
11

Distinguished, questioned or overruled (2)

CaseNegativeCited
State v. Knappgreen
wis · 2005 · cited in 2 Wisconsin opinions naming this issue, 2015–2016
2 sentences

2016When such transgressions are acknowledged yet forgiven by the courts, we endorse and invite their repetition." United States v. Olsen, 737 F.3d 625, 632 (9th Cir. 2013) (Kozinski, C.J., joined by four judges, dissenting from denial of rehearing en banc); see also Knapp, 285 Wis. 2d 86, ¶¶75, 79 . 18 See ¶134, infra (quoting Professor LaFave's criticism of a court's using the inevitable discovery doctrine under these circumstances). 6 No. 2014AP2238-CR.ssa Rather, the State challenges only the suppression of the physical evidence seized at Jackson's home. ¶113 The majority opinion agrees with t

2016In concluding that suppression of the physical evidence is necessary, I adhere to the reasoning in State v. Knapp, 2005 WI 127 , 285 Wis. 2d 86 , 700 N.W.2d 899 , which held that physical evidence obtained as a direct result of an intentional violation of Miranda is inadmissible under Article I, Section 8 of the Wisconsin Constitution. ¶116 In refusing to suppress the physical evidence obtained at Jackson's home, the majority opinion applies the inevitable discovery doctrine, an exception to the exclusionary rule.20 I disagree with applying the inevitable discovery doctrine in the instant case

12
State v. Garnergreen
nc · 1992 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
11

Also cited on this issue (32)

CaseCitedYears
State v. Anker green
wisctapp · 2014
2 sentences

2022Johnson argues that the independent source doctrine does not apply, while the State argues that the inevitable discovery doctrine does apply.6 These two doctrines are “related but distinct.” State v. Anker, 2014 WI App 107, ¶25 , 357 Wis. 2d 565 , 855 N.W.2d 483 .

2022Johnson argues that the independent source doctrine does not apply, while the State argues that the inevitable discovery doctrine does apply.6 These two doctrines are “related but distinct.” State v. Anker, 2014 WI App 107, ¶25 , 357 Wis. 2d 565 , 855 N.W.2d 483 .

22016–2022
State v. Pickens green
wisctapp · 2009
2 sentences

2011Avery relies on this court's holding in State v. Pickens, 2010 WI App 5 , 323 Wis. 2d 226 , 779 N.W.2d 1 , that the inevitable discovery rule requires "that the police be actively pursuing the legal alternative — here, a warrant — prior to the unlawful search." Id., ¶¶ 47-49.

2011Avery relies on this court's holding in State v. Pickens, 2010 WI App 5 , 323 Wis. 2d 226 , 779 N.W.2d 1 , that the inevitable discovery rule requires "that the police be actively pursuing the legal alternative — here, a warrant — prior to the unlawful search." Id., ¶¶ 47-49.

22011–2021
United States v. Jacobsen green
scotus · 1984
1 sentence

2026Based on the facts as they existed at the time of the officer’s search of the flash drive, the officer’s conduct was reasonable, and the officer’s conduct “did not infringe any constitutionally protected privacy interest that had not already been frustrated as the result of private conduct.” See id. at 126 . ¶16 The State raises alternative arguments, including the argument that the doctrine of inevitable discovery applies, to any expansion in the scope of the private search.

12026–2026
State v. Laverne Ware, Jr. green
wisctapp · 2021
2 sentences

2025For the reasons that follow, we conclude that the State has not shown that the facts of this case satisfy any of the justifications argued by the State for admitting the evidence obtained from the warrantless entry into Meloy’s garage.4 A. Exigent Circumstances ¶15 “Warrantless searches of homes are presumptively unreasonable.” State v. Ware, 2021 WI App 83, ¶19 , 400 Wis. 2d 118 , 968 N.W.2d 752 (internal 4 The State now concedes that there is no evidence that the officer was acting in a community caretaker capacity when he entered the garage.

2025For the reasons that follow, we conclude that the State has not shown that the facts of this case satisfy any of the justifications argued by the State for admitting the evidence obtained from the warrantless entry into Meloy’s garage.4 A. Exigent Circumstances ¶15 “Warrantless searches of homes are presumptively unreasonable.” State v. Ware, 2021 WI App 83, ¶19 , 400 Wis. 2d 118 , 968 N.W.2d 752 (internal 4 The State now concedes that there is no evidence that the officer was acting in a community caretaker capacity when he entered the garage.

12025–2025
State v. Clark green
wisctapp · 2003
2 sentences

2024Jackson, 369 Wis. 2d 673, ¶¶65, 67 . ¶10 An inventory search of a vehicle being taken into police custody is “a well-defined exception to the warrant requirement.” Colorado v. Bertine, 479 5 No. 2024AP617-CR U.S. 367, 371 (1987); State v. Clark, 2003 WI App 121, ¶11 , 265 Wis. 2d 557 , 666 N.W.2d 112 .

2024Jackson, 369 Wis. 2d 673, ¶¶65, 67 . ¶10 An inventory search of a vehicle being taken into police custody is “a well-defined exception to the warrant requirement.” Colorado v. Bertine, 479 5 No. 2024AP617-CR U.S. 367, 371 (1987); State v. Clark, 2003 WI App 121, ¶11 , 265 Wis. 2d 557 , 666 N.W.2d 112 .

12024–2024
State v. Kennedy green
wisctapp · 1986
2 sentences

2024Nor is there any question that the cocaine in Nelson’s cup holder would have been found in such a search; Goritz unequivocally testified that if he had not conducted the search of the vehicle before having it towed, the cocaine would have been found “regardless” in a later inventory search. ¶13 While conceding that our supreme court’s holding in Jackson makes clear that indicia of inevitability such as the active pursuit of an alternate line of investigation are not required elements for the applicability of the inevitable discovery doctrine, Nelson attempts to distinguish the case of State v.

2024Nor is there any question that the cocaine in Nelson’s cup holder would have been found in such a search; Goritz unequivocally testified that if he had not conducted the search of the vehicle before having it towed, the cocaine would have been found “regardless” in a later inventory search. ¶13 While conceding that our supreme court’s holding in Jackson makes clear that indicia of inevitability such as the active pursuit of an alternate line of investigation are not required elements for the applicability of the inevitable discovery doctrine, Nelson attempts to distinguish the case of State v.

12024–2024
State v. Carroll green
wis · 2010
2 sentences

2022“As applied to circumstances where an application for a warrant contains both tainted and untainted evidence, the issued warrant is valid if the untainted evidence is sufficient to support a finding of probable cause to issue the warrant.” See State v. Carroll, 2010 WI 8, ¶44 , 322 Wis. 2d 299 , 778 N.W.2d 1 .

2022“As applied to circumstances where an application for a warrant contains both tainted and untainted evidence, the issued warrant is valid if the untainted evidence is sufficient to support a finding of probable cause to issue the warrant.” See State v. Carroll, 2010 WI 8, ¶44 , 322 Wis. 2d 299 , 778 N.W.2d 1 .

12022–2022
Arizona v. Gant green
scotus · 2009
2 sentences

2020Second, Arizona v. Gant, 556 U.S. 332 (2009), could not apply to support a suppression motion here, because, in the words of trial counsel, “the officer thought that there was a valid warrant [for Jackson] at the time that the search was conducted and [the 4 The State makes no argument that trial counsel could have provided deficient performance in failing to identify a potential winning suppression argument as to only one of the counts of conviction (felon in possession or threatening a law enforcement officer) and not the other. 6 No. 2018AP2450-CR officer] was operating on” the belief that

2020In fact, on the search incident to arrest topic, the State’s brief on appeal fails even to mention Gant or allude in any way to the holding of that case that police may search a vehicle incident to a recent occupant’s arrest only when the arrestee is unsecured and within reaching distance of the passenger compartment at the time of the search or the vehicle contains evidence of the offense resulting in the arrest.7 See Gant, 556 U.S. at 343 . ¶22 The State’s only developed argument is based on the protective search exception to the Fourth Amendment.

12020–2020
State v. Daniel S. Iverson green
wis · 2015
12017–2017
State v. Brett W. Dumstrey green
wis · 2016
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. Charles v. Matalonis green
wis · 2016
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. Andy J. Parisi green
wis · 2016
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. Richard L. Weber green
wis · 2016
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. Patrick K. Kozel green
wis · 2017
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. David W. Howes green
wis · 2017
2 sentences

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

2017Fourth Amendment challenges in criminal cases include: State v. Howes, 2017 WI 18 , 373 Wis. 2d 468 , 893 N.W.2d 812 (a warrantless blood draw was constitutional under the exigent circumstances exception); State v. Kozel, 2017 WI 3 , 373 Wis. 2d 1 , 889 N.W.2d 423 (a warrantless blood draw was lawful because the EMT who drew the blood was acting under a physician's direction, the blood was drawn in a constitutionally reasonable manner, and the defendant did not object to the blood draw); State v. Weber, 2016 WI 96 , 372 Wis. 2d 202 , 887 N.W.2d 554 (an officer's entry into the defendant's gara

12017–2017
State v. West green
wis · 2011
12016–2016
State v. Doe green
wis · 1977
12016–2016
In Re United States green
· 1984
12016–2016
State v. Washington green
wisctapp · 1984
12016–2016
United States v. Matlock green
scotus · 1974
12016–2016
United States v. Jerrell Heath green
ca2 · 2006
12016–2016
State v. Weber green
wis · 1991
12016–2016
State v. Thorstad green
wisctapp · 2000
12011–2011
State v. Pallone green
wis · 2000
12006–2006
State v. Faust green
wis · 2004
12006–2006
Cady v. Dombrowski green
scotus · 1973
12006–2006
State v. Boggess green
wis · 1983
12006–2006
Cherry v. United States green
scotus · 1987
12003–2003
New York v. Quarles green
scotus · 1984
11996–1996
United States v. James Thomas Cherry green
ca5 · 1986
11996–1996
State v. Donovan green
wisctapp · 1979
11988–1988
State v. Friday green
wisctapp · 1987
11988–1988

Statutes the citing opinions construe

WI § Wis. Stat. § 808.10 (12) WI § Wis. Stat. § 971.31 (5) WI § Wis. Stat. § 752.31 (3) WI § Wis. Stat. § 968.11 (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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