State v. Wynne, 258 Or. App. 787

Deputies responded to a domestic disturbance at a home; they encountered the defendant walking nearby and offered him a ride back so he could retrieve his friend’s phone number from his mother’s mobile phone.
Defendant accepted, sat in the back of Deputy Elder’s patrol car, and asked to remain there to avoid his mother; Elder closed the rear door (it could not be opened from inside).
Deputies went to the house; defendant’s mother invited them in and led them through the house, where they observed drug paraphernalia and a baggie appearing to contain methamphetamine in plain view.
Elder returned about 40–45 minutes later, read Miranda rights, told defendant about the findings, and defendant volunteered that he had other drugs and then guided deputies to their location; deputies then arrested him.
Defendant moved to suppress the physical evidence and his statements, arguing he had been unlawfully seized while locked in the patrol car and that, but for that seizure, he would have been present to object to his mother’s consent to search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence discovered in the house and defendant’s statements must be suppressed because defendant was unlawfully seized in the patrol car, creating causal nexus to discovery	State: any seizure was consensual or justified; alternatively, no causal link between any unlawful seizure and the discovery	Defendant: he was unlawfully detained beyond his consent and, but for that detention, would have been physically present to object to his mother’s consent, so evidence should be suppressed	Court: assumed arguendo an unlawful seizure but held defendant failed to establish the minimal factual nexus (“but for” link) between detention and discovery; suppression denied
Whether mother’s consent validated the deputies’ entry despite defendant’s absence	State: mother’s voluntary consent authorized entry and items were in plain view	Defendant: as a cotenant he would have objected if present, making mother’s consent inadequate over his refusal	Court: did not reach constitutional conflict rule (e.g., Randolph) because record shows entry was independent of any detention and mother’s consent made the initial entry lawful

State v. Hall, 339 Or. 7 (2005) (establishes the Article I, section 9 exclusionary-rule framework and the requirement to show a minimal factual nexus)
State v. Ehly, 317 Or. 66 (1993) (standard of review for suppression rulings; factual findings binding if supported by record)
Georgia v. Randolph, 547 U.S. 103 (2006) (warrantless search over the express refusal of a physically present cotenant is unreasonable)
State v. Hinds, 225 Or. App. 470 (2009) (assumes unlawful stop but refuses suppression when no causal nexus to discovered evidence)
State v. Courtney, 242 Or. App. 321 (2011) (no factual nexus where lawful vehicle procedure made discovery independent of an earlier unlawful seizure)