Murray v. United States
Citation
487 U.S. 533 (1988)
Facts
Federal agents made a warrantless entry into a warehouse and observed bales of marijuana; they then obtained a search warrant without mentioning their initial entry, re-entered, and seized the marijuana as evidence.
Issue
Whether evidence is admissible under the independent source doctrine when agents observed it during an illegal entry but subsequently obtained a valid warrant that did not reference the prior entry.
Holding
The Court remanded to determine whether the warrant application was genuinely independent of the initial illegal entry — specifically, whether the agents would have sought the warrant absent the prior observations.
Rule
Independent source doctrine — evidence is admissible if discovered through a source wholly independent from the constitutional violation; the doctrine requires that the warrant was not prompted by the illegal entry and that the magistrate’s decision was not affected by it.