In consolidated appeals, the State challenged suppression of evidence obtained during an investigation of Sherri Lynn Jennings, while Jennings challenged the admission of statements made to investigators. The Court of Appeals of Georgia affirmed the rulings concerning consent, exigent circumstances, and the voluntariness of Jennings’s statements. It vacated the trial court’s implicit ruling on whether evidence obtained after Jennings’s statements and arrest was subject to the Fourth Amendment exclusionary rule. The court remanded for an express ruling on that issue and directed the trial court to address the related Fourth Amendment questions concerning the statements.