source doctrine in South Carolina

2026Moore, 429 S.C. at 478–79, 839 S.E.2d at 889 (quoting Copeland, 321 S.C. at 323 , 468 S.E.2d at 624 ); see also Nix v. Williams, 467 U.S. 431, 443 (1984) ("The independent source doctrine allows admission of evidence that has been discovered by means wholly independent of any constitutional violation.").

2020The State maintains this evidence would have been inevitably discovered because law enforcement "had the victim's phone in their possession[,]" and they "had every right to search the victim's phone." However, nowhere in the record does the State claim law enforcement pulled call logs from any of the victim's phones, or even if law enforcement's forensic examination equipment was capable of accessing the victim's iPhones' call logs.18 "The independent source doctrine allows admission of evidence that has been discovered by means wholly independent of any constitutional violation." Nix, 467 U.S

2026Still, "'courts have recognized several exceptions to the exclusionary rule,' including, among others, the independent source doctrine, inevitable discovery, and good-faith reliance." Id. (quoting State v. Adams, 409 S.C. 641 , 647 & n.3, 763 S.E.2d 341 , 345 & n.3 (2014)). "[T]he independent source doctrine allows trial courts to admit evidence obtained in an unlawful search if officers independently acquired it from a separate, independent source." Utah v. Strieff, 579 U.S. 232, 238 (2016).

2020See State v. Adams, 409 S.C. 641 , 647 & n.3, 763 S.E.2d 341 , 345 & n.3 (2014) (collecting cases).

2026Still, "'courts have recognized several exceptions to the exclusionary rule,' including, among others, the independent source doctrine, inevitable discovery, and good-faith reliance." Id. (quoting State v. Adams, 409 S.C. 641 , 647 & n.3, 763 S.E.2d 341 , 345 & n.3 (2014)). "[T]he independent source doctrine allows trial courts to admit evidence obtained in an unlawful search if officers independently acquired it from a separate, independent source." Utah v. Strieff, 579 U.S. 232, 238 (2016).

2020See State v. Adams, 409 S.C. 641 , 647 & n.3, 763 S.E.2d 341 , 345 & n.3 (2014) (collecting cases).

2026The independent source doctrine rests "upon the policy that, while the government should not profit from its illegal activity, neither should it be placed in a worse position than it would otherwise have occupied." Murray v. United States, 487 U.S. 533, 542 (1988). "[T]he inevitable discovery doctrine provides that illegally obtained information may nevertheless be admissible if the prosecution can establish by a preponderance of the evidence that the information would have ultimately been discovered by lawful means." Moore, 429 S.C. at 481, 839 S.E.2d at 890 (quoting State v. Cardwell, 425 S.

2026The independent source doctrine rests "upon the policy that, while the government should not profit from its illegal activity, neither should it be placed in a worse position than it would otherwise have occupied." Murray v. United States, 487 U.S. 533, 542 (1988). "[T]he inevitable discovery doctrine provides that illegally obtained information may nevertheless be admissible if the prosecution can establish by a preponderance of the evidence that the information would have ultimately been discovered by lawful means." Moore, 429 S.C. at 481, 839 S.E.2d at 890 (quoting State v. Cardwell, 425 S.

2026Moore, 429 S.C. at 478–79, 839 S.E.2d at 889 (quoting Copeland, 321 S.C. at 323 , 468 S.E.2d at 624 ); see also Nix v. Williams, 467 U.S. 431, 443 (1984) ("The independent source doctrine allows admission of evidence that has been discovered by means wholly independent of any constitutional violation.").

2026Moore, 429 S.C. at 478–79, 839 S.E.2d at 889 (quoting Copeland, 321 S.C. at 323 , 468 S.E.2d at 624 ); see also Nix v. Williams, 467 U.S. 431, 443 (1984) ("The independent source doctrine allows admission of evidence that has been discovered by means wholly independent of any constitutional violation.").

2026Still, "'courts have recognized several exceptions to the exclusionary rule,' including, among others, the independent source doctrine, inevitable discovery, and good-faith reliance." Id. (quoting State v. Adams, 409 S.C. 641 , 647 & n.3, 763 S.E.2d 341 , 345 & n.3 (2014)). "[T]he independent source doctrine allows trial courts to admit evidence obtained in an unlawful search if officers independently acquired it from a separate, independent source." Utah v. Strieff, 579 U.S. 232, 238 (2016).

2026The independent source doctrine rests "upon the policy that, while the government should not profit from its illegal activity, neither should it be placed in a worse position than it would otherwise have occupied." Murray v. United States, 487 U.S. 533, 542 (1988). "[T]he inevitable discovery doctrine provides that illegally obtained information may nevertheless be admissible if the prosecution can establish by a preponderance of the evidence that the information would have ultimately been discovered by lawful means." Moore, 429 S.C. at 481, 839 S.E.2d at 890 (quoting State v. Cardwell, 425 S.

2026The independent source doctrine rests "upon the policy that, while the government should not profit from its illegal activity, neither should it be placed in a worse position than it would otherwise have occupied." Murray v. United States, 487 U.S. 533, 542 (1988). "[T]he inevitable discovery doctrine provides that illegally obtained information may nevertheless be admissible if the prosecution can establish by a preponderance of the evidence that the information would have ultimately been discovered by lawful means." Moore, 429 S.C. at 481, 839 S.E.2d at 890 (quoting State v. Cardwell, 425 S.