State v. Wright, 391 S.C. 436

An anonymous tip in Nov 2006 led Clarendon County deputies to a mobile home on Jackson Road suspected of dogfighting.
Deputies observed many vehicles, spotlights, a dogfighting pit, and fleeing people and dogs from a dirt road near the mobile home.
A dogfighting scene and related paraphernalia were found; a search warrant was obtained the following day based on prior observations.
Respondents moved to suppress all evidence seized, arguing no warrant and no exigent circumstances; the circuit court granted suppression.
The State appealed; the South Carolina Supreme Court certified the case for review under Rule 204(b), SCACR.
The central issue is whether the evidence was properly seized under plain view and exigent-circumstances exceptions, without requiring inadvertent discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plain view after Horton: proper elements satisfied?	State: initial intrusion lawful; incriminating nature apparent; inadvertence unnecessary.	Coulette/Lyles: inadvertent discovery required; otherwise suppression appropriate.	Yes; inadvertent discovery not required; initial intrusion lawful and incriminating nature apparent.
Exigent circumstances and initial intrusion lawful?	State: anonymous tip plus fleeing suspects justified entry and protective sweep.	Coulette/Lyles: there was no lawful basis to enter; exigent circumstances insufficient.	Yes; initial intrusion lawful and exigent circumstances justified entry.

Beckham v. State, 334 S.C. 302, 513 S.E.2d 606 (1999) (plain view doctrine prerequisites)
Horton v. California, 496 U.S. 128, 110 S. Ct. 2301 (1990) (overruled inadvertence requirement for plain view)
State v. Herring, 387 S.C. 201, 692 S.E.2d 490 (2009) (exigent circumstances doctrine; protective sweep context)
Katz v. United States, 389 U.S. 347 (1967) (public exposure external to Fourth Amendment protection)
Mincey v. Arizona, 437 U.S. 385 (1978) (standard for warrantless searches and seizures)