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The independent-source doctrine permits admission of “evidence obtained pursuant to a warrant that is genuinely independent of a prior unlawful search and would have been obtained even if what actually happened had not occurred.” d 51, 55 (Minn. App. 1996) (quotation omitted).

2d 904, 910 (Minn. App. 2012) (considering appellant’s criminal history and change in supervisory status as two factors among others in a reasonable suspicion analysis), rev. denied (July 17, 2012); (“Arrests not resulting in conviction may be considered when the arrest was for an offense of the same general nature.”); (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”); (cautioning that “a criminal record .

(considering “appellant’s prior criminal record” in its probable-cause analysis); (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”).

State v. Lieberg , ( quotation omitted).

6 (“A person’s criminal record is among the circumstances a judge may consider when determining whether probable cause exists for a search warrant.”).

And raising such an issue for the first time on appeal is “particularly inappropriate” where the issue “involve[s] undeveloped questions of fact.”

-14 (Minn. 1965); d 51, 56 (Minn. App. 1996); rev. denied (Minn. Oct.

“This court generally will not decide issues which were not raised before the district court, including constitutional questi ons of criminal procedure.” Roby v. State , (concluding defendant forfeited challenge to probable cause determination by failing to raise issues at omnibus hea ring).

The independent-source doctrine, however, permit s “evidence obtained pursuant to a warrant that is genuinely independent of a prior unla wful search and would have been obtained ‘even if what actually happ ened had not occurred.’” (quoting Murray, 487 U.S. at 542 n.3, 108 S. Ct. at 2536 n.3).

(stating that a defendant’s criminal history may be properly considered as “one factor in the totality of relevant circumstances”).

” (quoting Murray v. United States, 487 U.S. 533, 536-37, 108 S. Ct. 2529, 2533 (1988)).

State v. Brunes , review denied (Minn. Oct.

Whether law enforcement would have discovered evidence absent an illegal search is a factual determination “which mu st receive initial consideration by the trial court.”

See Murray v. United States, 487 U.S. 533, 542, 108 S. Ct. 2529, 2536 (1988) (stating that evidence based on a warrant would not be admissible if law enforcement sought the warrant because of a p rior illegal entry or “if information obtained during that entry was presented to the Mag istrate and affected his decision to issue the warrant”); State v. Lieberg , (“The exclusionary rule generally requires the suppression of evidence acquired as a direct or indirect result of an unlawful search.”).

See State v. Lieberg , (citing Murray v. United States, 487 U.S. 533, 536-37, 108 S. Ct. 2529, 2533 (1988)).

A probable cause determination involves a practical, common-sense decision given all of the circumstances, 6 whether “there is a fair probability that contraband or evidence of a crime will be found in a particular place.” (quotation omitted).

for a search warrant.” see United States v. Conley, 4 F.3d 1200, 1207 (3d Cir. 1993) (stating that the use of prior convictions to aid in establishing probable cause is not only permissible, but helpful, especially when the present matter involves the same criminal behavior as the previous conviction)

(concluding that probable cause to search existed based in part on the appellant’s three arrests for drug-related offenses and conviction of a fourth-degree controlled-substance crime); -57 (Minn. App. 1996) (determining that the defendant’s entire history of criminal behavior was properly considered as a factor in evaluating the totality of the circumstances for probable cause).

“The exclusionary rule generally requires the suppression of evidence acquired as a direct or indirect result of an unlawful search.”

“The exclusionary rule generally requires the suppression of evidence acquired as a direct or indirect result of an unlawful search.”

While the exclusionary rule generally requires the suppression of evidence acquired as a result of an unlawful search, the “Constitution does not require suppression of evidence that was obtained through an independent source.”

see also Murray v. United States, 487 U.S. 533, 542, 108 S. Ct. 2529, 2536 (1988) (stating that “[t]he ultimate question, therefore, is whether the search pursuant to warrant was in fact a genuinely independent source of the information”).

(holding that while criminal history cannot, by itself, establish probable cause, it can be considered as one factor in the totality of relevant circumstances).