or the “water pipe” on top of the refrigerator, are subject to the plain view doctrine and could have validly been seized by Officer Lane during his initial entry to prevent the destruction of evidence. Consent to Search We now determine whether the evidence seized by Officer Lane that was not in plain view was nevertheless admissible because of the later voluntary consent to search by appellant. Consent to search is an established exception to the Fourth Amendment requirements that police have a warrant and probable cause to enter a residence. Brimage, 918 S.W.2d at 480. In cases in which consent follows an illegal arrest, courts have analyzed the consent to determine if it was tainted by the illegal police conduct. See e.g., Brick v. State, 738 S.W.2d 676, 677 (Tex.Crim. App.1987); (<HOLDING>). The primary purpose of determining whether
holding that escorting the defendant from a baggage claim area to a dea office approximately 75 yards away was an arrest and that his consent to the search of his bag in that office was tainted by the illegal seizure holding that the court of appeals erred in declining to consider whether the arrest was illegal and whether the consent was tainted by the potentially illegal police activity holding that initial illegal detention does not call into question validity of arrest pursuant to valid warrant wjhere the police effectuate an arrest in an illegal manner but nonetheless have probable cause to make the arrest the proper fourth amendment remedy is to exclude only that evidence which is a fruit of the illegality holding that statements obtained following an illegal arrest are no less tainted than is physical evidence obtained after the same holding that a cause of action for illegal arrest and false imprisonment accrued at the time plaintiff was released from his alleged illegal restraint and not when the proceedings by which his arrest occurred terminated