David Wright v. State of Indiana, 108 N.E.3d 307

FBI obtained a federal warrant for the upstairs unit at 220½ E. Water St. after an IP at that address accessed known child‑pornography sites; agents seized equipment from the upstairs unit and learned the two units shared an internet connection.
FBI Special Agent Robertson, without obtaining a separate warrant for the downstairs unit (Wright's residence), asked 220's occupants to either verbally consent to a search that day or leave until a warrant could be obtained; Wright and others gave verbal consent and surrendered computers and passwords.
Over the weekend agents ran forensic software on the seized devices and matched Wright’s device to known child‑pornography hashes; Monday agents returned, released most devices but retained Wright’s and Agent Robertson spoke privately with Wright in a car.
Robertson told Wright he was not under arrest and could leave; Wright voluntarily admitted using TOR and then admitted sexual contact with two children; Robertson then had local police arrest Wright, who was Mirandized and gave further statements to Detective Crouse.
Trial court suppressed evidence from the computer search (invalid consent) but declined to suppress Wright’s statements as attenuated from the illegal search; Wright was convicted and sentenced to 60 years; Court of Appeals reversed, holding attenuation does not apply under Article 1, §11; Indiana Supreme Court granted transfer.

Issue	State's Argument	Wright's Argument	Held
Whether Indiana's Article I, §11 permits the attenuation doctrine so that statements made after an illegal search can be admissible	Attenuation is a recognized limit to the exclusionary rule; statements here were attenuated by time, intervening events, and non‑flagrant police conduct	Attenuation has no place under Article I, §11; Wright's statements were fruit of the poisonous tree and must be excluded	The Court held Indiana embraces the attenuation doctrine; apply a totality‑of‑the‑circumstances test (timeline, intervening circumstances, police misconduct) and admitted the statements as attenuated
Whether Wright's 60‑year aggregate sentence is inappropriate	State urged affirmance (and resisted reduction)	Wright sought reduction to 30 years based on character and lack of criminal history	The Court found the sentence not inappropriate and affirmed the 60‑year term

Callender v. State, 193 Ind. 91, 138 N.E. 817 (Ind. 1923) (early adoption of exclusionary rule under Indiana Constitution)
Membres v. State, 889 N.E.2d 265 (Ind. 2008) (exclusionary rule’s primary objective is deterrence and protection of privacy)
Wong Sun v. United States, 371 U.S. 471 (1963) (announcing attenuation doctrine / fruit of the poisonous tree analysis)
Brown v. Illinois, 422 U.S. 590 (1975) (attentuation factors: temporal proximity, intervening circumstances, flagrancy of misconduct)
Utah v. Strieff, 136 S. Ct. 2056 (2016) (recent U.S. Supreme Court discussion of attenuation and its three‑factor inquiry)
Shotts v. State, 925 N.E.2d 719 (Ind. 2010) (describing Indiana’s totality‑of‑the‑circumstances reasonableness test under Article I, §11)