had, a short time earlier, arrested the intended suspect. However, after Valez was taken out of the arresting officer’s car at the police station, 15 packets of cocaine were found under his seat. The Second Circuit indicated that these packets of cocaine “provided independent probable cause to support Valez’s arrest.” Id. at 26. S/A Tipton argues that Valez, therefore, supports the proposition that evidence discovered after an arrest can provide probable cause for the arrest. However, earlier in its opinion, the Second Circuit held that the fact that Valez matched the suspect's description gave the arresting officer probable cause at the time of the arrest. See id. at 26. Thus, there was no defect in the original arrest that required cure. I 96 S.Ct. 3021, 3032, 49 L.Ed.2d 1046 (1976) (<HOLDING>). This is because the deterrent purposes of the
holding that exclusionary rule does not extend to proceedings other than criminal trials holding that exclusionary rule to be applied as a matter of state law is no broader than the federal rule holding that exclusionary rule does apply to civil forfeiture proceedings holding that exclusionary rule applies to civil forfeiture proceedings holding that exclusionary rule does not extend to forbid the use in federal civil tax proceeding of evidence illegally seized by state criminal law enforcement agent