The facts of the case, Murray v. United States, are detailed, along with the Court's reasoning. The author points out that the Murray decision, by permitting the admission of evidence first discovered during an illegal warrantless search, appears to erode the fourth amendment exclusionary rule, which requires the suppression of evidence seized during an unlawful search. However, the author continues, the holding is firmly grounded in the principles underlying the exclusionary rule. The key to preventing erosion is to ensure that a legal search following the illegal search is in fact a genuinely independent search. Additionally, courts should examine the circumstances surrounding the first illegal search and look to whether the law enforcement officers conducting that search did so in good faith. 227 footnotes.