of $229. On appeal, Sledge renews his challenge to the search incident to the arrest, arguing the officers unlawfully detained, pat-searched, and physically restrained him, and that Sledge’s actions, whether or not a violation of state law, did not remove the taint of the illegal arrest. II. DISCUSSION “When considering a suppression order, we review the district court’s factual fin ime during an unlawful detention, the Fourth Amendment’s exclusionary rule does not bar evidence of the new crime.” United States v. Hunt, 372 F.3d 1010, 1012, (8th Cir.2004). “A contrary rule would virtually immunize a defendant from prosecution for all crimes he might commit that have a sufficient causal connection to the police misconduct.” United States v. Bailey, 691 F.2d 1009, 1017 (11th Cir.1982) (<HOLDING>). In denying Sledge’s motion to suppress, the
holding a defendants response to even an invalid arrest  may constitute independent grounds for arrest holding that if a suspects response to an illegal stop is itself a new distinct crime then the police constitutionally may arrest the suspect for that crime holding that duress is a defense available in new mexico except when the crime charged is a homicide or a crime requiring intent to kill holding prosecutor has discretion to charge defendant under general crime even though more specific crime exists holding police may legally arrest a defendant for a new distinct crime even if the new crime is in response to police misconduct and causally connected thereto