People v. Superior Court, 204 Cal. App. 4th 1004

Police responded to a shooting at Carl Chapman’s home; Chapman was detained and his girlfriend identified him as shooter.
A protective sweep and a post-sweep observation found shell casings, a gun, blood, and damage in plain view but no initial seizure.
Chapman was arrested; detectives later reentered the home to process the scene and seized plain-view items observed during the first-entry sweep.
The trial court suppressed the second-wave observations and evidence, concluding no exigency or consent justified a second warrantless entry after death and arrest.
The People challenged the suppression, arguing plain-view and inevitable-discovery exceptions and consent supported admissibility; the trial court separately suppressed a confession questioned under Miranda.
The appellate court granted the petition in part, reversing suppression of plain-view evidence and certain non-plain-view shell casing and depression evidence as inevitable discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether second-wave entry were lawful	People: second entry justified by ongoing processing and plain view.	Chapman: no exigency or consent to reenter after death/arrest; must have warrant.	Second-wave plain-view observations/seizures upheld; no further warrant needed.
Whether plain-view evidence obtained by second wave was admissible	Plain-view seizure valid once in residence due to consent/exigent circumstances.	Suppression proper because second entry lacked independent justification.	Plain-view evidence admissible; observations properly seized.
Whether the inevitable-discovery doctrine applies to non-plain-view items	Shell casing and depression would have been discovered inevitably by coroner processing.	No equitable inevitable-discovery where warrant was available and Fourth Amendment violated.	Inevitable discovery doctrine applies to non-plain-view shell casing and depression; suppressions reversed.
Whether Chapman’s statements to Umansky were tainted by fruit of the poisonous tree	Umansky’s questions were based on observations observed in plain view by first wave.	Statements tainted by unlawful seizure of non-plain-view evidence.	Statements not suppressed; taint not established for questions tied to bloodstains within scope of initial entry.

People v. Williams, 45 Cal.3d 1268 (Cal. 1988) (exclusionary rule and taint-based suppression standards)
McDowell, 46 Cal.3d 551 (Cal. 1988) (uninterrupted police presence allows later plain-view seizure)
Justin, 140 Cal.App.3d 729 (Cal. App. 1983) (waiver of privacy extends to subsequent entries when plain view evidence)
Ngaue, 8 Cal.App.4th 896 (Cal. App. 1992) (reentry to retrieve plain-view gun observed during arrest valid)
Robles, 23 Cal.4th 789 (Cal. 2000) (inevitable discovery doctrine limits where warrant would have been required)
Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (general homicide scene exception not recognized as warrantless blanket rule)
Thompson v. Louisiana, 469 U.S. 17 (U.S. 1984) (murder-scene exploration exception not recognized as warrantless rule)
Duncan, 42 Cal.3d 91 (Cal. 1986) (emergency ends when danger dissipates; exigency must justify continued entry)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (plain-view seizure requires lawful access and probable cause)