In Flippo v. West Virginia, 528 U.S. 11; 120 S Ct 7; 145 L. Ed. 2d 16 (1999), the United States Supreme Court again addressed the warrantless seizure of evidence in the context of a murder investigation. In Flippo, the defendant called police to a state park cabin, reporting that he and his wife had been attacked. Id. When police officers arrived, they found defendant standing outside the cabin with injuries to his head and legs and they discovered the defendant's wife inside, suffering from fatal head wounds. Id. The officers secured the scene and other officers arrived thereafter to both (1) search the cabin and (2) to process evidence. Id. During the warrantless search, the police officers found a closed briefcase which they opened and discovered inside an envelope containing several photographs and negatives. Id. The United States Supreme Court declined to consider the jury issue of whether the defendant had consented to the search, holding that the warrantless seizure of items in the briefcase violated the Fourth Amendment because the Court in Mincey rejected the general "crime scene exception" to the warrant requirement. Id. at 8-9.