the ten minutes or so between being awakened and providing consent, Kyer’s mother took that time to compose herself and to listen to the officers explain why they came to her apartment and why they entered it uninvited. By itself, however, this brief duration does not put the attenuation inquiry to an end. It is just one of several considerations. Even a very short duration need not negate the efficacy of a voluntary consent. See, e.g., Seidman, 156 F.3d at 548 (finding a few minute period between entry and consent insufficient to negate consent); Sheppard, 901 F.2d at 1235 (“Even though the time span between the challenged conduct and Sheppard’s consent was short, we cannot find that the second search resulted from the exploitation of the challenged conduct.”); Owen, 453 So.2d at 1207 (<HOLDING>). III. In sum, we hold that the trial court
holding that although temporal proximity alone may show causation the proximity must be very close and action taken  20 months later suggests by itself no causality at all holding that close temporal proximity is sufficient to establish a prima facie case of retaliation holding that a three to four month period between the protected activity is not enough to show very close temporal proximity holding that consent was valid despite close temporal proximity between the illegal entry and consent holding that a close temporal proximity between a public employees speech and a defendants actions suggested a causal relationship