Pursuant to rule 24(i), Utah Rules of Appellate Procedure, I am citing United States v. Segura, 468 U.S. 796, 815-816 & n.10 (1984), and United States v. Corral- Corral, 899 F.2d 927, 930 (10th Cir. 1990), as supplemental authority in support of the State's argument that the inevitable discovery doctrine requires no absolute proof, beyond evidence of predictable police routine, of what would have hypothetically occurred absent the illegality. See Cross-Pet. Reply Br. at 3-7, 11-13. This case is scheduled for oral argument on Wednesday, 7 May 2003.
Public record document (some rights may be reserved).
Legal Brief, Utah v. Topanotes, No. 20010127 (Utah Supreme Court, 2001).