an earlier unconstitutional search and seizure of evidence. See Gonzalez, 71 F.3d at 829-30 (deciding whether the police’s illegal entry into the owner’s kitchen should be deemed coercive activity that affected the owner’s later consent to search other parts of the premises); Tovar-Rico, 61 F.3d at 1535-36 (deciding whether the defendant’s initial oral consent to enter the apartment and her subsequent written consent to conduct a thorough search were voluntary). The only cited case that addresses the precise issue is Weaver. In that case, the Oregon Supreme Court held that the timing of the consent in and of itself was not dispositive. Instead, relying on the proposition that the consenting party is the person who determines the scope of the consent, the court stated in di 303-05 (<HOLDING>), cert. denied, 437 U.S. 907, 93 S.Ct. 3098, 57
holding that the defendants subsequent written consent given with the full knowledge that the police had previously entered his house without a warrant amounted to a waiver of the warrant requirement and rendered the earlier search and seizure valid holding that a search exceeded the scope of the initial oral consent and was not validated by a subsequent written consent an allegedly consensual seizure must stand or fall on the basis of the consent preexisting the seizure holding that consent was freely and voluntarily given despite officers advisement that the police could get a search warrant if consent was not given holding that an arrest warrant  without a search warrant  does not permit law enforcement authorities to enter a third partys home to legally search for the subject of the arrest warrant holding warrant valid where search warrant application affidavit was signed and probable cause existed for issuance of warrant