Wilder v. State, 290 Ga. 13

Wilder was convicted on multiple counts of child molestation and related crimes involving a 15-year-old victim and was sentenced as a recidivist to life without parole plus additional terms.
A locked briefcase owned by Wilder was seized from a third party’s premises without a warrant and later searched under a valid warrant.
The briefcase contained explicit videos, tapes, and highlighted code provisions related to crimes against minors.
The seizure occurred after an officer obtained information from the victim and a witness and arranged for the briefcase to be retrieved from a third party, Malin.
The trial court denied the motion to suppress, ruling either on consent by Malin or the independent source doctrine; the Court of Appeals affirmed the result on independent source grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge seizure	Wilder has standing to challenge seizure of his property.	Wilder lacks standing to challenge third-party premises seizure.	Wilder has standing to contest seizure.
Independent source doctrine applicability	Independent source allowed admission since warrant-based search relied on independent information.	Independent source should apply because information used for the warrant was independent of the initial seizure.	Independent source doctrine does not apply.
Effect of unlawful seizure on admissibility	Evidence should be admissible if independently discovered, regardless of the unlawful seizure.	Evidence should be suppressed as fruits of an unlawful seizure since the seizure enabled the search.	Evidence cannot be admitted under independent source; reflexive analysis remanded for other issues.
Third-party consent and bailees	Consent by Malin could validate seizure as third-party consent.	Bailment and third-party consent doctrines are unsettled under these facts.	We decline to decide on third-party consent/bailee at this stage; remand appropriate.
Inevitable discovery doctrine	Inevitable discovery could justify admission.	Inevitable discovery was not proven here.	Inevitable discovery not decided; remand for briefing.

Teal v. State, 282 Ga. 319 (Ga. 2007) (independent source doctrine in Georgia context)
Lejeune v. State, 277 Ga. 749 (Ga. 2004) (independent source doctrine in search-warrant context)
Price v. State, 270 Ga. 619 (Ga. 1999) (independent source doctrine, consent search viability)
Murray v. United States, 487 U.S. 533 (U.S. 1988) (independent source concept in illegality-fruits analysis)
United States v. Jacobsen, 466 U.S. 109 (U.S. 1984) (definition of seizure vs. search; Fourth Amendment scope)