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Travis Joe Littlev.The State

CourtCourt of Appeals of Georgia
Docket No.A19A1758
DecidedFebruary 10, 2020
Reporter269 Ga. App. 760
JudgesCourt of Appeals of Georgia
Tags
CriminalCriminal LawCriminal ProcedureFourth AmendmentSearch and SeizureWarrantless SearchMotion to SuppressReversal
Case Summary

Travis Little was convicted of controlled-substance offenses after officers entered a camper behind his mother’s house without a warrant. The officers relied on an unidentified report that Little was moving methamphetamine and later obtained consent after entering the home and encountering him. The Georgia Court of Appeals held that the State failed to prove a valid exception to the warrant requirement. The initial entry was unlawful, and the evidence seen inside, the later consent search, and Little’s statements were fruits of that entry rather than sufficiently attenuated discoveries. Because the State bore the burden of proving the search lawful and the suppression record presented no credibility dispute requiring deference, the court reversed the suppression ruling and the convictions.

Opinion

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