Wehrenberg, Michael Fred

OPINION

delivered the opinion of the Court

Is the federal independent source doctrine, which excepts from the exclusionary rule evidence initially observed during an unlawful search but later obtained lawfully through independent means, applicable in Texas? The State raises this question in its petition for discretionary review after the court of appeals reversed two felony drug convictions of Michael Fred Wehren-berg, appellant, on the grounds that the trial court erred by applying that doctrine as a basis to deny appellant’s motion to suppress. Wehrenberg v. State, 385 S.W.3d 715 (Tex.App.-Fort Worth 2012) (holding that independent source doctrine is inconsistent with Texas’s exclusionary rule and thus inapplicable in this State). We agree with the State that the independent source doctrine poses no conflict with Article 38.23 of the Texas Code of Criminal Procedure, the statutory exclusionary rule in Texas that requires suppression of evidence “obtained” in violation of the law. See Tex.Code Crim. Proc. art. 38.23; Segura v. United States, 468 U.S. 796, 813-14, 104 S.Ct. 3380, 82 L.Ed.2d 599 (1984) (holding that exclusion of evidence as fruit of the poisonous tree was “not warranted” because “there was an independent source for the warrant under which [the challenged] evidence was seized”). Because the independent source doctrine does not circumvent or avoid the statutory exclusionary rule’s requirement that evidence obtained in violation of the law be suppressed, we conclude that the court of appeals erred by rejecting that doctrine as a basis for upholding the trial court’s suppression ruling. We reverse and remand.

I. Background and Procedural History

A. Facts and Trial Proceeding

A police anti-narcotics unit had been conducting surveillance of a Parker County residence for approximately thirty days when officers received a call from a confidential informant advising them that the occupants were preparing to manufacture methamphetamine that night. Several hours after receiving that call, at approximately 12:30 a.m., officers entered the residence without a search warrant and with-: out consent. Upon entering the residence, the officers encountered several individuals, including appellant, whom they handcuffed and escorted to the front yard. Officers performed a protective sweep of the residence, determined that no methamphetamine was being “cooked” at that time, and then went back outside the residence. Two investigators then prepared the search-warrant affidavit. The affidavit relied only on information provided by the confidential informant and did not mention the officers’ warrantless entry into the residence. In relevant part, the affidavit stated that the informant had “provided information detailing narcotics manufacture and trafficking” at appellant’s residence and had, within the past 72 hours, “personally observed the suspected parties in possession of certain chemicals with intent to manufacture a controlled substance.” The affidavit additionally stated that, according to the confidential informant, the subjects were planning to use the “shake and bake” method of manufacturing methamphetamine, which the affiant described as “fast” and “often utilized to prevent detection of the illicit laboratory by law enforcement personnel.”

*462At 1:50 a.m., approximately one-and-a-half hours after the officers’ initial entry into the residence, the magistrate signed the search warrant. Police officers conducted a search of the residence and discovered methamphetamine and implements for manufacturing methamphetamine. Appellant was arrested and charged with possession of chemicals with intent to manufacture methamphetamine and possession of methamphetamine weighing more than 4 but less than 200 grams.1

Appellant moved to suppress the evidence, arguing that the officers’ warrant-less entry was unlawful and that all evidence seized thereafter was subject to suppression. The State, in response, argued that the search warrant was a valid basis for admitting the challenged evidence. At the hearing on the motion to suppress, the trial court heard testimony from Investigator Montanez, one of the officers who had prepared the search-warrant affidavit. Regarding the initial entry, Montanez stated that upon receiving the informant’s tip that the subjects were “fixing to cook methamphetamine,” the officers decided to “pull[ ] everybody out of the house and place[] them in the front yard” in order to “keep from evidence being destroyed.” Montanez additionally explained that it was necessary to “secure the residence” because the process of “cooking” methamphetamine via the “shake-and-bake method” is “volatile” and “hazardous” in that it can cause explosions and/or fire, and he was “afraid that [the subjects] would begin making methamphetamine and then a fire would break out.” Regarding the search warrant, Montanez testified that the affidavit’s contents were based solely on the confidential informant’s tip. He stated that he left to go get the warrant signed “immediately after appellant and his co-defendants were detained, and that he returned to the scene around 2 a.m., at which time the search warrant was executed.

The trial court granted in part and denied in part appellant’s motion to suppress. Announcing his ruling, the trial judge stated that the officers’ initial entry into the residence was “without a lawful warrant, exigent circumstances, or other lawful basis,” and that, therefore, “any evidence from that search and seizure during that entry and detention at the initial entry to the home is suppressed.” The trial judge went on to explain, however, that evidence seized pursuant to the search warrant was not subject to suppression because the search-warrant affidavit did not “allude to or mention the previous entry of the home, nor the detention of the suspect inhabitant defendants,” and, therefore, the warrant was “untainted by the previous entry and detention.”2 Appellant subsequently pled guilty pursuant to a plea-bargain agreement and was sentenced to five years’ confinement on each count, to run concurrently. Appellant expressly reserved his right to appeal the trial court’s ruling on the motion to suppress.

*463B. Court of Appeals’s Holding and Arguments on Discretionary Review

In the court of appeals, appellant contested the trial court’s conclusion that the search warrant could serve as a valid basis for admitting the challenged evidence. He argued that (1) the officers’ initial entry into the residence was unjustified by any exception to the warrant requirement and thus constituted an unlawful search, and (2) officers obtained information during that unlawful search that later served as the basis for the search-warrant affidavit, and, therefore, the warrant was “tainted from the use of information gained in and from the warrantless entry of the home.” Appellant essentially disputed the trial court’s assessment that the search-warrant affidavit was based solely on information provided by the confidential informant, but he did not directly argue that the independent source doctrine was inapplicable in this State. In response to appellant’s arguments, the State contended that suppression was not required because (1) the officers’ initial entry into the residence was justified by exigent circumstances, and, alternatively (2) the search warrant was a valid basis for admitting the challenged evidence under the independent source doctrine because it was issued based solely on information provided by the confidential informant and thus was untainted by any pre-warrant intrusion into the residence.

After agreeing with appellant and the trial court that the officers’ initial entry into the residence was unlawful, the court of appeals held that the trial court erred by finding that the search warrant was a valid basis for admitting the challenged evidence under the independent source doctrine. See Wehrenberg, 385 S.W.3d at 727-29. Although the court of appeals agreed with the State’s contention that this case “would appear to fall squarely within the parameters of the independent source doctrine” because “all of the information contained in the search warrant affidavit was derived from facts that were made known to [the officers] by the confidential informant before the warrantless entry into the residence,” it ultimately concluded that the doctrine was inapplicable in Texas, for three reasons. Id. at 727. First, the court of appeals noted that it had declined to adopt the independent source doctrine in its prior opinion in Oliver v. State. Id. (citing 711 S.W.2d 442, 445 (Tex.App.-Fort Worth 1986, pet. ref'd)) (reasoning that both inevitable discovery and independent source doctrines constitute “judicial exceptions to the judicially articulated exclusionary rule,” and declining to apply those doctrines because Texas’s statutory exclusionary rule plainly “contains no exceptions”). Second, the court of appeals noted that this Court has, on at least two prior occasions, in State v. Daugherty and Garcia v. State, “declined to recognize that the federal inevitable discovery doctrine is an exception to the statutory Texas exclusionary rule.” Id. (citing State v. Daugherty, 931 S.W.2d 268, 269-73 (Tex.Crim.App.1996); Garcia v. State, 829 S.W.2d 796, 798-800 (Tex.Crim.App. 1992)). Although it recognized that this Court’s opinions in Daugherty and Garcia addressed only the inevitable discovery doctrine, not the independent source doctrine, the court of appeals reasoned that those two doctrines are “actually two sides of the same coin,” and, therefore, this Court’s rejection of the inevitable discovery doctrine in those cases necessarily implied that the independent source doctrine should similarly be rejected. Id. at 727-28 (quoting United States v. Grosenheider, 200 F.3d 321, 327 (5th Cir.2000)). Third, the court of appeals noted that this Court has “not squarely addressed whether or not the independent source doctrine applies in Texas,” although it acknowledged that this Court has, on one prior occasion, *464suggested in dicta that the doctrine is applicable. Id. at 728-29 (citing State v. Powell, 306 S.W.3d 761, 769 (Tex.Crim. App.2010)). On these bases, the court of appeals held that the independent source doctrine was inapplicable and could not serve as a valid basis for upholding the trial court’s suppression ruling. Id.

In its petition for discretionary review, the State contends that the court of appeals erred by holding that the independent source doctrine conflicts with Texas’s statutory exclusionary rule. It argues that evidence obtained through an independent source has “no causal link” to the prior instance of illegal activity, and that such evidence, therefore, “is not obtained in violation of the law” within the meaning of the Texas exclusionary rule. Moreover, the State contends that the independent source doctrine is actually more compatible with the Texas exclusionary rule than the attenuation doctrine, a related doctrine that this Court has embraced, and that it is analytically distinct from the inevitable discovery doctrine, which this Court has rejected. Appellant responds that the court of appeals correctly concluded that the independent source doctrine is inapplicable in this State, or, alternatively, that the doctrine would not apply to his case because the search-warrant affidavit was based on evidence unlawfully observed by officers during their initial entry into the residence. This Court granted the State’s petition to determine whether the court of appeals erred by holding that the independent source doctrine conflicts with the statutory exclusionary rule and is inapplicable in Texas.3 We agree with the State’s contentions and hold that the independent source doctrine is applicable in Texas.

II. Independent Source Doctrine Provides for Admissibility of Untainted Evidence

A. General Scope of Independent Source Doctrine

Before answering the question of whether the independent source doctrine is consistent with the plain terms of the Texas exclusionary rule, we must first define the scope of that doctrine. We initially note that the federal exclusionary rule generally requires suppression of both primary evidence obtained as a direct result of an illegal search or seizure, as well as derivative evidence acquired as an indirect result of unlawful conduct. See Segura, 468 U.S. at 804, 104 S.Ct. 3380 (exclusionary remedy “ ‘extends as well to the indirect as the direct products’ of unconstitutional conduct”) (quoting Wong Sun v. United States, 371 U.S. 471, 484, 83 S.Ct. 407, 9 L.Ed.2d 441 (1963)). The Supreme Court has, however, developed several exceptions to this rule, including the independent source doctrine. That doctrine was first referred to by the Supreme Court in Silverthome Lumber Company v. United States, in which the Court recognized that facts do not become “sacred and inaccessible” simply because they are first discovered unlawfully; rather, “[i]f knowledge of [facts] is gained from an independent source they may be proved like any others[.]” 251 U.S. 385, 392, 40 S.Ct. 182, 64 L.Ed. 319 (1920). The Supreme Court has subsequently elaborated on this principle on several occasions. See Murray v. United States, 487 U.S. 533, 537, 108 S.Ct. *4652529, 101 L.Ed.2d 472 (1988); Segura, 468 U.S. at 814-16, 104 S.Ct. 3880; Nix v. Williams, 467 U.S. 431, 443, 104 S.Ct. 2501, 81 L.Ed.2d 377 (1984).

In Segura, the Supreme Court explained that “[i]t has been well established for more than 60 years that evidence is not to be excluded if the connection between the illegal police conduct and the discovery and seizure of the evidence is ‘so attenuated as to dissipate the taint.’ It is not to be excluded, for example, if police had an ‘independent source’ for discovery of the evidence[.]” Segura, 468 U.S. at 805, 104 S.Ct. 3380 (quoting Nardone v. United States, 308 U.S. 338, 341, 60 S.Ct. 266, 84 L.Ed. 307 (1939)). At its core, the independent source doctrine provides that evidence derived from or obtained from a lawful source, separate and apart from any illegal conduct by law enforcement, is not subject to exclusion. Nix, 467 U.S. at 443, 104 S.Ct. 2501 (describing doctrine as permitting “admission of evidence that has been discovered by means wholly independent of any constitutional violation”); Murray, 487 U.S. at 537, 108 S.Ct. 2529 (stating that independent source doctrine permits introduction of “evidence initially discovered during, or as a consequence of, an unlawful search, but later obtained independently from activities untainted by the initial illegality”).4 Thus, in determining whether challenged evidence is admissible under the independent source doctrine, the central question is “whether the evidence at issue was obtained by independent legal means.” United States v. May, 214 F.3d 900, 906 (7th Cir.2000).5

B. Segura v. United States

Segura v. United States established that, notwithstanding a prior instance of unlawful police conduct, evidence actually discovered and obtained pursuant to a valid search warrant is not subject to suppression, so long as the police would *466have sought the warrant regardless of any observations made during the illegal entry. See Segura, 468 U.S. at 799, 813-15, 104 S.Ct. 3380.6 In Segura, the question before the Supreme Court was whether suppression was required after the police, acting on a tip regarding possible drug-trafficking activity, entered the defendant’s apartment without his consent and conducted a security sweep of the residence. Id. at 799-801, 104 S.Ct. 3380. No search warrant was obtained until the next day, 19 hours after the initial entry, at which point a search was conducted and several items of evidence were discovered and seized, including weapons, cash, and several pounds of cocaine. Id. None of these items was observed by officers during the initial entry; rather, they were discovered for the first time during the subsequent search pursuant to the warrant. Id. at 804, 104 S.Ct. 3380. After determining that the initial entry into the defendant’s apartment had been unlawful, the Supreme Court nevertheless concluded that the evidence seized • pursuant to the search warrant need not be excluded “as derivative or fruit of the poisonous tree” because of the existence of an “independent source.” Id. at 813-14, 104 S.Ct. 3380. Explaining its ruling, the Court stated that suppression was not warranted because the “evidence [was] discovered during the subsequent search of the apartment the following day pursuant to the valid search warrant,” and the warrant was “issued wholly on information known to the officers before the entry into the apartment.” Id. at 799, 104 S.Ct. 3380. It further observed that “[n]one of the .information on which the warrant was secured was derived from or related in any way to the initial entry into petitioners’ apartment.” Id. at 814, 104 S.Ct. 3380. The information supporting the search warrant instead “came from sources wholly unconnected with the entry and was known to the agents well before the initial entry.” Id. Because “[n]o information obtained during the initial entry or occupation of the apartment was needed or used by the agents to secure the warrant,” the officers’ preexisting knowledge provided an independent source for the discovery and seizure of the evidence. Id. Given that the illegal entry had nothing to do with the later discovery and seizure of evidence pursuant to the warrant, the Court deemed that evidence untainted and admissible. See Hudson v. Michigan, 547 U.S. 586, 600, 126 S.Ct. 2159, 165 L.Ed.2d 56 (2006) (describing Segura as distinguishing “the effects of the illegal entry from the effects of the legal search”). Moreover, Segura instructs that the existence of an independent source makes the exclusionary rule inapplicable because it “breaks the causal chain between the constitutional violation alleged and the discovery of the evidence challenged.” United States v. Scott, 270 F.3d 30, 44 (1st Cir. 2001).

C. Murray v. United States

Subsequent to Segura, the Supreme Court has explained that the independent source doctrine is broad enough to encompass both (1) evidence observed and obtained for the first time during an independent lawful search following a previous instance of unlawful police conduct, which was the factual situation in Segura, and (2) evidence observed in plain view during an initial unlawful entry but later “obtained independently from activities un*467tainted by the initial illegality,” the situation presented in Murray. Murray, 487 U.S. at 542, 108 S.Ct. 2529. In Murray, after receiving a tip from an informant, federal drug-enforcement agents entered a warehouse by force and without a warrant, at which time they observed drugs in plain view. Id. at 535, 108 S.Ct. 2529. The officers then left the warehouse without disturbing the drugs, but kept the location under surveillance. Id. Eight hours later, the agents secured a search warrant based solely on information already in their possession prior to the initial entry. They then re-entered the warehouse and seized 270 bales of marijuana. Id. at 535-36, 108 S.Ct. 2529. In holding that the drugs were not tainted by the initial entry and not subject to suppression, the Supreme Court explained that, although “[kjnowl-edge that the marijuana was in the warehouse was assuredly acquired at the time of the unlawful entry,” it was “also acquired at the time of entry pursuant to the warrant, and if that later acquisition was not the result of the earlier entry there is no reason why the independent source doctrine should not apply.” Id. at 541, 108 S.Ct. 2529. So long as the later, lawful seizure was “genuinely independent of an earlier, tainted one,” the independent source doctrine would apply to carry the challenged evidence outside the scope of the exclusionary remedy. Id. Murray thus stands for the proposition that, in cases involving a warrant obtained after an initial unlawful search during which officers observed the evidence in plain view, the challenged evidence is nevertheless admissible so long as the “search pursuant to warrant was in fact a genuinely independent source of the information and tangible evidence at issue.” Murray, 487 U.S. at 542,108 S.Ct. 2529.7

Reading Segura and Murray in conjunction, we observe that the core function of the independent source doctrine is to remove from the scope of the federal exclusionary rule evidence that is actually discovered through an independent source and thus is untainted by the prior instance of unlawful police conduct. Having defined the contours of the doctrine, we now turn to the question of whether application of that doctrine is consistent with Texas’s statutory exclusionary rule. See Baker v. State, 956 S.W.2d 19, 23 (Tex.Crim.App. 1997) (noting that “whether a recognized exception to a federal exclusionary rule also applies to Article 38.23 depends upon whether the exception is consistent with the language of Article 38.23”).

III. Independent Source Doctrine Consistent With Texas Exclusionary Rule

The primary dispute in this case centers on whether evidence derived from an independent source following a prior instance of unlawful police conduct is nevertheless “obtained” in violation of the law, thereby requiring suppression under Texas’s statutory exclusionary rule. See Tex.Code Crim. Proc. art. 38.23. The State contends that, contrary to appellant’s contention and the conclusion reached by the court of appeals, evidence acquired pursuant to an independent source is not actually “obtained” in violation of the law because it is *468not derived in any way from a prior instance of illegal conduct. See Segura, 468 U.S. at 814, 104 S.Ct. 3380; Murray, 487 U.S. at 542, 108 S.Ct. 2529. It argues that, because there is no causal connection between the prior illegality and the seizure of evidence, suppression is not required under Article 38.23. We agree with the State that evidence obtained pursuant to an independent source, much like evidence for which a prior taint has been attenuated, is not “obtained” in violation of the law and is thus not subject to suppression. See Tex.Code Crim. Proc. art. 38.23; Johnson v. State, 871 S.W.2d 744, 750-51 (Tex.Crim.App.1994) (holding that federal attenuation doctrine is consistent with Article 38.23 because “evidence sufficiently attenuated from the violation of the law is not considered to be ‘obtained’ therefrom”). We, therefore, conclude that the court of appeals erred by rejecting that doctrine as a basis for upholding the trial court’s suppression ruling. See Wehrenberg, 385 S.W.3d at 728-29.

A. Unlawfully “Obtained” Evidence Must Be Excluded Under Texas Exclusionary Rule

The Texas exclusionary rule provides in relevant part that “No evidence obtained ... in violation of any provisions of the Constitution or laws of the State of Texas, or of the Constitution or laws of the United States of America, shall be admitted in evidence against the accused on the trial of any criminal case.” Tex.Code Crim. Proc. art. 38.23. To determine the meaning of this provision, we examine its plain language. See Boykin v. State, 818 S.W.2d 782, 785-86 (Tex.Crim.App.1991); see also Daugherty, 931 S.W.2d at 270 (examining plain language of Article 38.23); Johnson, 871 S.W.2d at 750 (same); Garcia, 829 S.W.2d at 799 (same).

Evidence is “obtained” if it is “possessed,” “gained or attained,” usually “by planned action or effort.” Webster’s New Collegiate Dictionary 816 (9th ed.1988); see also Daugherty, 931 S.W.2d at 270 (same). Applying this definition in the context of the Texas exclusionary rule, the word obtained means that evidence is acquired by planned action or effort, or, more specifically, by seizure. Id. Applying this ordinary definition, this Court has previously interpreted Article 38.23 to mean that evidence is “obtained” in violation of the law only if there is some causal connection between the illegal conduct and the acquisition of evidence. Roquemore v. State, 60 S.W.3d 862, 870 (Tex.Crim.App. 2001); Daugherty, 931 S.W.2d at 270 (“Once the illegality and its causal connection to the evidence have been established, the evidence must be excluded” under Article 38.23). Conversely, if there is no causal connection, then the evidence cannot be said to have been “obtained” in violation of the law and thus is not subject to exclusion under the statute. Daugherty, 931 S.W.2d at 270-71; Powell, 306 S.W.3d at 770 n. 18 (noting in dicta that “[a]bsent a ‘but-for’ causal connection between any unlawful seizure ... and the discovery of [evidence], our state exclusionary rule ... would not require exclusion”); Sorto v. State, 173 S.W.3d 469, 487 n. 71 (Tex.Crim.App.2005) (suppression not warranted because, among other factors, there was no showing of “any causal connection” between purported violation of law and challenged evidence). The existence of a but-for causal connection between the illegality and the obtainment of evidence is thus a prerequisite to application of the statutory exclusionary rule, for without at least some causal link, the evidence is not properly understood as having been “obtained” unlawfully, as an ordinary person would interpret that term. See Daugherty, 931 S.W.2d at 270; Johnson, 871 S.W.2d at 750.

*469Furthermore, this Court has long recognized that evidence is not “obtained” in violation of the law within the plain meaning of Article 38.23 if the taint from the illegality has dissipated by the time the evidence is acquired. Johnson, 871 S.W.2d at 750. In Johnson, this Court adopted the federal attenuation doctrine as being consistent with the express provisions of Article 38.23 because “evidence sufficiently attenuated from the violation of the law is not considered to be ‘obtained’ therefrom.” Id. at 750-51. The Court further reasoned that the attenuation doctrine was not an impermissible non-statutory exception to the exclusionary rule, but rather was “a method of determining whether evidence was ‘obtained’ in violation of the law, with ‘obtained’ being included in the plain language of the statute.” Id. at 751; see Wong Sun, 371 U.S. at 487-88, 83 S.Ct. 407 (describing attenuation analysis as being an inquiry into “whether, granting establishment of the primary illegality, the [challenged] evidence ... has been come at by exploitation of that illegality or instead by means sufficiently distinguishable to be purged of the primary taint”); State v. Mazuca, 375 S.W.3d 294, 300 n. 18 (Tex.Crim.App.2012) (noting that attenuation doctrine “applies in determining whether evidence has been unlawfully ‘obtained’ for purposes of’ Article 38.23).

In State v. Daugherty, the Court reaffirmed the correctness of its approach in Johnson with respect to the attenuation doctrine. 931 S.W.2d at 270-71. It noted that “[t]he ordinary meaning of ‘obtained’ may accommodate the attenuation doctrine inasmuch as, depending on how removed the actual attainment of the evidence is from the illegality, the ordinary person would not consider that evidence to have been ‘obtained’ by that illegality.” Id. at 270 (observing that, under plain-language interpretation of Article 38.23, there is “a point beyond which the ‘ordinary understanding’ of obtained just does not apply”). Thus, when the causal relationship between the illegality and the acquisition of evidence is attenuated, exclusion is not required because the “ordinary meaning of ‘obtained’ does not extend to such a remote, or ‘attenuated,’ causal relationship.” Id. at 270-71.

As we observe above, the independent source doctrine provides that evidence actually obtained pursuant to a distinct, untainted source is not subject to suppression because, in such cases, the prior illegality does “not contribute in any way to discovery of the evidence seized under the warrant.” Segura, 468 U.S. at 815,104 S.Ct. 3380 . In cases involving an independent source, “not even the threshold ‘but for’ requirement” is met. Id.; see also United States v. Crews, 445 U.S. 463; 471, 100 S.Ct. 1244/63 L.Ed.2d 537 (1980); Murray, 487 U.S. at 539, 108 S.Ct. 2529. Because the independent source doctrine is applicable only to situations in which there is no causal link between the illegal conduct and the discovery or seizure of evidence, application of that doctrine is entirely consistent with the statutory exclusionary rule’s requirement that evidence “obtained” in violation of t