Ex parte Jarvis Lamar Bridgett

Summary

The Supreme Court of Alabama reviewed whether marijuana seized from a lockbox was inadmissible as fruit of an allegedly illegal seizure of keys. The court held that Bridgett voluntarily consented to the use of the keys and that the consent was sufficiently attenuated from any prior illegality, affirming the denial of his motion to suppress.

Holdings

1. Bridgett voluntarily consented to the officers' use of the keys to unlock and search the lockbox.
2. When consent to search follows allegedly illegal police activity, the court must determine both whether the consent was voluntary and whether it was sufficiently attenuated from the illegality to purge the taint. Bridgett's consent was not tainted, even assuming the keys were illegally seized.

Questions Presented

1. Whether Bridgett voluntarily consented to the officers' use of the keys on his key ring to open the lockbox.
2. Whether, assuming the keys were illegally seized, Bridgett's consent was sufficiently attenuated from the alleged illegality so that the marijuana was not fruit of the poisonous tree.
3. Whether the Court of Criminal Appeals' decision conflicted with Wong Sun v. United States and Harris v. State.

Disposition

affirmed