If an officer engaging in a consensual encounter with a citizen discovers an arrest warrant, the arrest is valid and any evidence discovered during a search incident to arrest is admissible. See United States v. Robinson, 414 U.S. 218, 235, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973) (emphasizing that search incident to arrest requires no additional justification). Consent, however, is the hallmark of such an encounter. ¶ 8 Although the trial court found Officer Lewis’s encounter with Hummons consensual, the court of appeals assumed, without deciding, that Officer Lewis illegally detained Hummons before discovering the warx’ant and then arresting and searching him. The court therefore considered whether the search was sufficiently attenuated fi’om any i 945 P.2d 1260, 1275 (1997) (<HOLDING>). ¶ 12 The court of appeals, however,
holding that the courts determination of whether an officer had probable cause for an arrest is an independent and objective determination and an officers own subjective reason for the arrest is irrelevant holding that motive of officers is generally irrelevant to fourth amendment analysis holding that probable cause to believe the traffic code had been violated rendered the stop reasonable under the fourth amendment regardless of officers subjective intent holding that as long as officers possess a valid warrant the subjective intent of officers is irrelevant holding by failing to raise it to the district court the government waived its argument the subjective intent of the officers was irrelevant for establishing probable cause