State of Tennessee v. John B. Alberts, 354 S.W.3d 320

Appellant Alberts was indicted in Williamson County for eight counts of rape of a child, one count of solicitation of a minor to commit rape of a child, and one count of solicitation of sexual exploitation of a minor.
Detectives investigated after parents reported sexual abuse; a prior conviction for oral sex with a minor was discovered.
Search of a laptop and digital camera in Appellant’s car allegedly yielded images of sexual conduct with minors seized pursuant to a warrant obtained by Lt. Denton.
Trial court suppressed the evidence, holding the search warrant invalid; the State sought interlocutory review to consider a warrantless search exception.
Court held that the trial court should evaluate whether a warrantless search based on probable cause and exigent circumstances exists, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court may consider a warrantless search exception after invalidating a warrant	State argues court may assess exceptions to the warrant requirement	Albert argues no such consideration should occur	Remand to determine if a warrantless exception applies

State v. Keith, 978 S.W.2d 861 (Tenn. 1998) (probable cause standards; warrant validity context)
State v. Jacumin, 778 S.W.2d 430 (Tenn. 1989) (four-corners rule for probable cause)
State v. Yeargan, 958 S.W.2d 626 (Tenn. 1997) (exigent circumstances doctrine; warrant exceptions)
State v. Walton, 41 S.W.3d 75 (Tenn. 2001) (de novo review; suppression standard framework)
State v. Henning, 975 S.W.2d 290 (Tenn. 1998) (pretrial suppression review; admissibility evidence considerations)
State v. Garcia, 123 S.W.3d 335 (Tenn. 2003) (warranted search and exceptions principles)