This Note analyzes the Young court’s opinion and the potential consequences of the majority’s cursory rejection of the government’s inevitable discovery argument. This Note also reconciles the differing applications of the inevitable discovery doctrine by the Young majority and dissent and highlights the speculative nature of employing the inevitable discovery doctrine based on the facts of Young. Part I of this Note presents the background of the case and the historical development of Fourth Amendment jurisprudence, focusing on the inevitable discovery doctrine as articulated by the Supreme Court in Nix v. Williams. Part II outlines the Young decision and analyzes Young’s expectation of privacy in comparison with other cases involving similar facts and the inevitable discovery doctrine. Part II also discusses the dissent’s vigorous, but misguided, argument in favor of applying the inevitable discovery doctrine to Young’s case. Part III discusses the potential consequences of the majority’s cursory examination of the inevitable discovery doctrine and presents a more in-depth analysis of why the inevitable discovery doctrine does not apply in this case.
Lauren Young Epstein,
Limits of the Inevitable Discovery Doctrine in United States v. Young: The Intersection of Private Security Guards, Hotel Guests, and the Fourth Amendment, 40 Golden Gate U. L. Rev.