United States v. McManaman, 673 F.3d 841

McManaman was indicted on gun and drug charges based on 2005–2006 admissions.
Authorities served an arrest warrant at his home; he was arrested on the porch after being informed of the warrant.
During the initial search, officers found drugs and a shotgun; McManaman volunteered information about a hidden gun.
Officers opened a locked closet with consent and discovered child pornography materials; Frye later consented to a follow-up search.
A suppression hearing found a Fifth/Sixth Amendment violation but concluded inevitable discovery would render evidence admissible; district court adopted this, and McManaman pled guilty to earlier charges.
Subsequently, an eight-count indictment charged new child-pornography offenses; McManaman challenged suppression again, arguing violations tainted evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence would have been inevitably discovered by lawful means.	McManaman argues no probable cause or alternative line of investigation.	McManaman argues no lawful path to the later discovery.	Inevitably discovered evidence doctrine applied; evidence admissible.
Whether collateral estoppel bars relitigation of inevitable discovery.	Prior ruling estops re-argument of prongs.	Due process concerns may bar estoppel in criminal cases.	Collateral estoppel applies; McManaman barred from re-litigating prongs.
Whether plain-view justification supports admission of pornography evidence.	Evidence discovered within scope of warrant could be seized under plain view.	Photographs/videos not immediately apparent as incriminating.	Plain-view applies; incriminating nature apparent; evidence admissible.
Whether Third-Prong/taint from initial interrogation tainted evidence.	Evidence would have been discovered inevitably regardless of interrogation.	Interrogation violations tainted subsequent searches.	Inevitable discovery doctrine renders violations moot; evidence admissible.

Segura v. United States, 468 F.2d 796 (U.S. 1984) (exclusionary rule scope and taint avoidance principles)
Nix v. Williams, 467 U.S. 431 (U.S. 1984) (inevitable discovery standard; taint purge)
Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (plain-view and incremental discovery under lawful search)
United States v. Ross, 456 U.S. 798 (U.S. 1982) (scope of search warrants and container searches)
United States v. Evans, 966 F.2d 398 (8th Cir. 1992) (plain view within warrant scope in closet/box scenarios)