How have courts interpreted the inevitable discovery doctrine in the context of an illegal search?

[80 Cal.App.3d 678] United States v. Paroutian (2d Cir. 1962) 299 F.2d 486, 489. "Since the search was illegal, and defendant has introduced substantial evidence showing that the heroin and the letter were uncovered as a result of this illegal search, the burden shifted to the government, which then was under an obligation to prove that its evidence had an independent origin. . . . Had the government shown that it had knowledge of the secret compartment from an independent source, the evidence would of course have been admissible."

Courts of our sister states also have generally implemented the inevitable discovery doctrine. We advert again to typical authority.

Santiago v. State (Tex.Cr.App.1969) 444 S.W.2d 758, 761. "Even appellant's counsel admitted that in the normal course of investigation the police would have discovered the existence of Gerchak as a witness. Under the circumstances, it is clear that the testimony of Gerchak would have been obtained regardless by means sufficiently distinguishable from the underlying illegality to be purged of the primary taint. . . . The locating of the witness would not have remained unknown 'but for' the confession."

Cook v. State (1969) 8 Md.App. 243, 259 A.2d 326, 335. "In the case before us we think that the evidence was sufficient for the court to find that the officer, considering the information the evidence showed he had, would have searched the car for contraband or evidence of the crimes without the statement of the appellant as to the location of the gun and that the evidence was obtained from a source independent of the illegal question."