CASES ARE CONSIDERED IN RELATION TO THE TWIN PURPOSES UNDER PINNING THE EXCLUSIONARY RULE - DETERRENCE OF FEDERALLY UNCONSITITIONAL STATE ACTIONS AND PRESERVATION OF JUDICIAL INTEGRITY. AND THE RELATIVE DECLINE IN IMPORTANCE OF THE 'JUDICIAL INTEGRITY' RATIONALE IS NOTED. THE DISTINCTION IS ALSO MADE BETWEEN UNCONSTITUTIONALLY AND ILLEGALLY SEIZED EVIDENCE. THE AUTHORS CONCLUDE THAT IF A FORUM COURT DETERMINES THAT A SEARCH WAS 'UNCONSTITUTIONAL' UNDER ITS INTERPRETATION OF THE FEDERAL CONSTITUTION, THE EVIDENCE MUST BE CONSIDERED UNCONSTITUTIONAL REGARDLESS OF WHERE IT WAS SEIZED AND REGARDLESS OF WHETHER THE COURTS OF THE SEARCH JURISDICTION CONSIDER THE SEARCH CONSTITUTIONALLY VALID. THREE DIFFERENT SITUATIONS ARISE WITH 'ILLEGALLY' OBTAINED EVIDENCE. WHERE THE EVIDENCE WAS ILLEGALLY OBTAINED UNDER THE LAW OF THE SEARCH JURISDICTION AND WOULD ALSO BE CONSIDERED ILLEGALLY SEIZED UNDER THE LAW OF THE FORUM, THE AUTHORS MAINTAIN THAT THE EXCLUSIONARY RULE SHOULD BE APPLIED. THEY ARRIVE AT THE OPPOSITE CONCLUSION IN SITUATIONS WHERE THE EVIDENCE IS DETERMINED TO BE ILLEGALLY SEIZED IN THE SEARCH JURISDICTION, BUT IS NOT REGARDED AS IMPROPERLY OBTAINED ACCORDING TO THE LAW OF THE FORUM. THEY ALSO SUGGEST THAT THE EIVDENCE BE ADMITTED WHERE THE SEIZURE OF EVIDENCE IS VALID UNDER THE LAW OF THE SEARCH JURISDICTION BUT WOULD BE REGARDED AS UNLAWFUL HAD IT OCCURRED IN THE FORUM.