Wilder v. State, 320 Ga. App. 497

Wilder was convicted after a jury trial of statutory rape, aggravated child molestation, two counts of child molestation, and two counts of sexual exploitation of a child involving a 15-year-old.
On appeal, this court affirmed portions but reversed on the independent source doctrine; the Georgia Supreme Court reversed and remanded for possible inevitable discovery and third-party consent analysis.
On remand, the trial court held that both inevitable discovery and third-party consent doctrines applied, denying the suppression motion.
A briefcase containing explicit material and code excerpts was obtained after a private seizure by a citizen, but initiated by police activity.
The officer collected information before the seizure showing the briefcase was at a specific home and that it contains relevant videotapes, leading to a warrant for its contents.
The court affirmed the suppression ruling based on inevitable discovery, concluding the evidence would have been discovered lawfully regardless of the initial seizure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Inevitable discovery applies	Wilder challenges the ruling on inevitable discovery	State contends lawful means would inevitably discover the evidence	Inevitable discovery applies; admissible
Third-party consent need not be resolved	Wilder argues the seizure was unlawful without third-party consent	State urges resolution on inevitable discovery suffices	Not necessary to decide; affirmed on inevitable discovery

Schweitzer v. State, 319 Ga. App. 837 (Ga. App. 2013) (inevitable discovery framework and application)
Teal v. State, 282 Ga. 319 (Ga. 2007) (precedes inevitable discovery standard and factors)
Fincher v. State, 276 Ga. 480 (Ga. 2003) (motion to suppress upheld if correct for any reason)
Taylor v. State, 274 Ga. 269 (Ga. 2001) (inevitable discovery considerations in police investigations)