Tatum v. State

Summary

The court held that the independent source doctrine requires consideration of whether the decision to seek a warrant was prompted by an earlier unlawful search, in addition to whether the warrant affidavit remains supported by probable cause after excision of tainted information. Because the trial court made no findings on that question and the appellate record was insufficient to resolve it, the court vacated the Court of Appeals' decision and directed that the trial court's judgment be vacated and the matter remanded for further proceedings.