State v. Lopez
In State v. Lopez, 207 Wis. 2d 413, 427-28, 559 N.W.2d 264 (Ct. App. 1996), the police obtained a warrant to search Lopez's house for marijuana. Lopez, 207 Wis. 2d at 421, 423.
During the execution of the warrant, one of the officers located a locked freezer in the basement. See Lopez, 207 Wis. 2d at 427.
Although Lopez had not been read Miranda warnings, the officer asked him where he could find the key to the freezer, and Lopez disclosed the key's location. See id.
Lopez argued that the marijuana in the freezer should have been suppressed as a fruit of his statement the police obtained in violation of Miranda. See id.
The court agreed with Lopez that the police had unlawfully elicited Lopez's statement about the location of the key. See id.
However, the court determined that the marijuana in the freezer was admissible under the inevitable discovery doctrine. See Lopez, 207 Wis. 2d at 427-28.
Because the police had already decided to search the freezer when they asked Lopez about the key, they were actively pursuing an alternate line of investigation. See id.