A framework, which might guide judges in the exercise of discretion, was derived from a wide variety of airport consent search cases. The first step in analyzing any consent search is to ask whether the suspect was seized. In order to make this determination, three groups of factors should be analyzed: the police conduct, the characteristics of the suspect, and the environment of the encounter. If the judge determines that the suspect was not seized, the next step is to ask whether he voluntarily consented to the search of his person or possessions. If, however, a court decides the suspect was seized, the analysis moves along an entirely different track. The first question is whether or not the seizure was legal. If it was legal, then the court returns to the same voluntariness inquiry it engages in when analyzing a purely voluntary encounter. If the suspect was seized illegally, however, the court must determine whether the consent was tainted by the illegal seizure.