AT COMMON LAW ALL EVIDENCE WAS ADMITTED REGARDLESS OF ANY ILLEGAL MEANS USED TO PROCURE IT. HOWEVER, THE U.S. SUPREME COURT ENUNCIATED THE EXCLUSIONARY RULE IN WEEKS V. UNITED STATES (1914), STATING THAT UNLAWFULLY OBTAINED EVIDENCE MUST BE EXCLUDED FROM CRIMINAL PROCEEDINGS. SUBSEQUENT CASES EXTENDED THE EXCLUSION TO ANY EVIDENCE OBTAINED AS A RESULT OF THE INITIAL ILLEGAL SEARCH AND SEIZURE. NEVERTHELESS, THE DOCTRINE HAS DEVELOPED EXCEPTIONS, ESPECIALLY WHEN DERIVATIVE EVIDENCE IS OBTAINED FROM AN INDEPENDENT SOURCE, OR WHEN THE CONNECTION BETWEEN THE EVIDENCE AND THE INITIAL ILLEGALITY IS ATTENUATED. THE TEST IS WHETHER THE CHALLENGED EVIDENCE HAS BEEN PROCURED BY EXPLOITATION OF THE PRIMARY ILLEGALITY OR BY ACTIONS SUFFICIENTLY DISTINGUISHABLE FROM THE ILLEGALITY TO PURGE THE TAINT. WITH THE CASE OF UNITED STATES V. CECCOLINI (1978) THE U.S. SUPREME COURT CONTINUES ITS WAR OF ATTRITION UPON THE FOURTH AMENDMENT EXCLUSIONARY RULE. CONSIDERING DERIVATIVE EVIDENCE IN THE FORM OF LIVE-WITNESS TESTIMONY FOR THE FIRST TIME, THE COURT REJECTED A PER SE RULE FOR ADMITTING SUCH EVIDENCE AND HELD THAT LIVE-WITNESS TESTIMONY IS SUBJECT TO THE EXCLUSIONARY RULE UNLESS AN EXCEPTION CAN BE MET. IN CECCOLINI THE COURT FOUND THE REQUISITE CONNECTION LACKING IN THE LIGHT OF THE WITNESS'S VOLUNTARY DECISION TO TESTIFY, AND THE LACK OF PURPOSEFULNESS OF THE POLICE SEARCH. THE COSTS OF EXCLUDING TTHE EVIDENCE WOULD HAVE BEEN DISPROPORTIONATE TO THE BENEFITS. THE CECCOLINI COURT REAFFIRMS THE USE OF A BALANCING TEST, AND PROVIDES STRONG PRECEDENT FOR THE ADMISSION OF TAINTED TESTIMONY. FOOTNOTES ARE INCLUDED. (TWK)