Because of possible undesirable consequences of the exclusionary rule, courts have fashioned exceptions that permit the introduction of such evidence when its suppression would not serve the purpose of deterrence. The inevitable discovery doctrine, one such exception, permits the introduction of illegally obtained evidence if the prosecutor can prove that such evidence would have been lawfully discovered in the course of a routine, predictable investigation. Courts have been sharply divided over the appropriateness of admitting incriminating evidence discovered during a warrantless search but seized after obtaining a warrant. This issue will be resolved by the U.S. Supreme Court in Murray v. United States in which officers observed evidence in plain view during an unlawful entry and then seized it pursuant to a search warrant. It is argued that the U.S. Supreme Court should show its unwillingness to sanction unreasonable police conduct by endorsing an approach consistent with the deterrence rationale. Instead of admitting prewarrant evidence under an inevitable discovery rationale, the Court should remand the case to the district court to determine if the officers harbored an objectively reasonable belief that exigent circumstances justified the warrantless entry leading to the discovery of the evidence. 215 footnotes.