Blackwell, Justice.

Brandon A. Bullard, James C. Bonner, Jr., Margaret E. Bullard, for appellant. Darius T. Pattillo, District Attorney, Sharon L. Hopkins, Assistant District Attorney, for appellee. Sean J. Young, Kosha S. Tucker, Nathan F. Wessler, Jennifer S. Granick, Riana Pfefferkorn, amici curiae.

After he was tried and convicted of two vehicular homicides, Victor Mobley appealed, claiming that the trial court erred when it denied his pretrial motion to suppress evidence of data that law enforcement officers retrieved without a warrant from an electronic data recording device on his vehicle. In denying the motion to suppress, the trial court had concluded that, whether or not the retrieval of the data was an unlawful search and seizure, the evidence was admissible in any event under the inevitable discovery doctrine. In Mobley v. State, 346 Ga. App. 641, 816 S.E.2d 769 (2018), a three-judge panel of the Court of Appeals affirmed, one judge reasoning that the retrieval of data was not a search and seizure at all, and two judges agreeing with the trial court that the inevitable discovery doctrine applied. We issued a writ of certiorari to review the decision of the Court of Appeals, and for the reasons that follow, we conclude that the trial court erred when it denied the motion to suppress. The judgment of the Court of Appeals, therefore, is reversed.

1. On the afternoon of December 15, 2014, Mobley was driving a 2014 Dodge Charger on Flippen Road in Henry County. A 1999 Chevrolet Corvette pulled onto Flippen Road from a private driveway, and the Charger collided with it. Mobley survived the crash, but the two occupants of the Corvette did not. At first, the law enforcement officers who responded to the scene of the collision found no indication that Mobley had been driving too fast. Indeed, based on their preliminary assessment of the scene and their initial discussions with witnesses, the officers thought it likely that the driver of the Corvette had caused the collision simply by driving into the path of the Charger.

But before the vehicles were removed from the scene of the collision, Sergeant David Gagnon—a supervisor in the Traffic Division of the Henry County Police Department—directed officers to retrieve any available data from the airbag control modules (ACM) on the Charger and Corvette. Investigator Jason Hatcher entered the passenger compartments of both vehicles, attached a crash data retrieval (CDR) device to data ports in the cars, and used the CDR to download data from the ACMs. The data retrieved from the Charger indicated that, moments before the collision, Mobley was driving nearly 100 miles per hour. The officers subsequently cleared the scene and had the Charger and Corvette both towed to an impound lot for further investigation. The next day, Investigator Bryan Thornton joined the team of officers investigating the collision. He discussed the case with the officers who had responded to the crash, visited and personally inspected the scene of the collision, and then applied for a warrant to search the Charger and Corvette and to physically remove and seize the ACMs from both vehicles. When Investigator Thornton made his application for a warrant, he was aware that Investigator Hatcher already had retrieved the data from the ACMs and that the data indicated that the Charger had been traveling at an excessive rate of speed. His application, however, did not rely on the data to establish probable cause for the seizure of the ACMs. A magistrate issued the warrant, officers executed the warrant at the impound lot, and the ACMs were removed from both vehicles. It appears, however, that no additional data was retrieved from the ACMs subsequent to the execution of the warrant.

In June 2015, a Henry County grand jury indicted Mobley, charging him with two counts of vehicular homicide in the first degree, reckless driving, and speeding. Mobley later filed a motion pursuant to OCGA § 17-5-30 to suppress the evidence of the data retrieved without a warrant from the ACM in his Charger, alleging that the retrieval of data was an unreasonable search and seizure forbidden by the Fourth Amendment. The trial court held an evidentiary hearing on the motion in June 2017, and at that hearing, the prosecuting attorney presented the testimony of Sergeant Gagnon, Investigator Hatcher, and Investigator Thornton.

Following the presentation of evidence, the prosecuting attorney argued that the motion to suppress should be denied for several reasons. More specifically, she argued that:

• Mobley had no reasonable expectation of privacy with respect to the data, and for that reason, the retrieval of that data was not a search and seizure for purposes of the Fourth Amendment;

• Even if the retrieval of the data was a search and seizure, a warrant was unnecessary because the search was directed to an automobile;

• Exigent circumstances—namely, the possibility that the data could be lost or corrupted when the vehicles were towed away from the scene—permitted a warrantless search;

• Investigator Hatcher retrieved the data without a warrant in good faith reliance on his understanding that no warrant is required to retrieve data from an ACM at the scene of a serious crash; and

• The subsequent issuance of a warrant to seize the ACMs made the discovery of the data inevitable.

On the day after the hearing, the trial court entered an order denying the motion to suppress. Without deciding whether the retrieval of data at the scene of the collision was a search and seizure that ordinarily would require a warrant, and without determining whether any established exception to the warrant requirement applied, the trial court concluded that the subsequent issuance of a warrant to seize the ACMs rendered the evidence admissible under the inevitable discovery exception to the exclusionary rule:

The Court finds that it does not have to reach the decision on the appropriateness of the actions of the officers on the scene because a search warrant was obtained the next day. [Investigator] Thornton testified that he always seeks such a warrant in accidents involving fatalities. A review of the warrant application and supporting affidavit shows that neither the application nor the affidavit relied upon information obtained from the on-the-scene download. The Court finds that the data contained in the ACM would have

certainly been available to law enforcement when the ACMs were properly removed from the vehicles pursuant to the search warrant[ ], and thus would have inevitably been discovered by investigators.

Mobley then stipulated to the relevant facts for purposes of a bench trial, and the trial court found him guilty on all counts. He was sentenced to concurrent terms of fifteen years—with seven years to be served in prison, followed by eaight years on probation—on two counts of vehicular homicide in the first degree.

Mobley appealed, challenging the denial of his motion to suppress. The Court of Appeals issued a split panel decision, rejecting the claim that the trial court erred when it denied the motion and affirming the judgment of conviction. Judge Mercier wrote the lead opinion, although she wrote only for herself. Judge Mercier concluded that the trial court properly denied the motion to suppress because the data retrieved from the ACM in the Charger was not of a sort in which Mobley could have a reasonable expectation of privacy. See Mobley, 346 Ga. App. at 646 (1), 816 S.E.2d 769. Noting that the data simply reflected the operation and movements of the Charger in the moments immediately preceding the collision, Judge Mercier explained that "[a] person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another." Id. at 645 (1), 816 S.E.2d 769 (citation and punctuation omitted). Although Judge Mercier conceded that "an outside observer cannot ascertain the information regarding the use and functioning of a vehicle with the same level of precision as that captured by the ACM," she said that most of the information that could be gleaned from the data was, in fact, ascertainable by any observer, albeit with less precision:

For example, a member of the public can observe a vehicle's approximate speed; observe whether a vehicle's brakes are being employed by seeing the vehicle slow down or stop or the brake lights come on, [or] by hearing the sounds of sudden braking; and observe whether the driver is wearing a seatbelt. There is no reasonable expectation of privacy in such information because an individual knowingly exposes such information to the public.

Id. at 646 (1), 816 S.E.2d 769. Because Mobley had no reasonable expectation of privacy in the data, Judge Mercier concluded, its retrieval at the scene of the collision did not amount to a search and seizure and did not, therefore, implicate the Fourth Amendment. See id. at 644 (1), 816 S.E.2d 769.

Then-Chief Judge Dillard and Presiding Judge Doyle wrote separately, both resting their concurrences on the inevitable discovery exception to the exclusionary rule. Judge Dillard focused on the testimony of the officers at the hearing on the motion to suppress about the usual course of investigation in cases involving a fatality accident. Specifically, Judge Dillard pointed to evidence that the retrieval of data from ACMs is routine in such investigations, as well as the testimony of Investigator Thornton that, if data had not been retrieved from the ACM at the scene, he would have sought a warrant and obtained the same data later. See id. at 648-649, 816 S.E.2d 769 (Dillard, C.J., concurring specially). Judge Doyle focused more on the warrant that was issued on the day following the collision, reasoning that it was obtained in the ordinary course of investigation, it did not rest on any information gleaned from the data retrieved without a warrant, and the data "inevitably would have been available to police pursuant to the warrant they later lawfully obtained." Id. at 652, 816 S.E.2d 769 (Doyle, P.J., concurring specially).

Mobley then filed a petition for a writ of certiorari. We granted his petition not only to consider the alternative grounds upon which the judges below concluded that the motion to suppress properly was denied, but also to decide whether OCGA § 17-5-30 categorically precludes the application of the inevitable discovery doctrine—or any other exception to the exclusionary rule—in Georgia. We now proceed to consider these issues in turn, addressing whether the retrieval of data from the ACM on the Charger was a search and seizure that implicates the Fourth Amendment; if so, whether the retrieval of the data without a warrant was an unreasonable search and seizure forbidden by the Fourth Amendment; if so, whether OCGA § 17-5-30 forecloses consideration of any exception to the exclusionary rule; and if not, whether the inevitable discovery doctrine is applicable on the facts before us. Along the way, we also will consider whether any of the other grounds that the State urged in the trial court for denying the motion to suppress, but upon which none of the judges below relied, require a remand for further proceedings in the trial court.

2. To begin, we consider whether the retrieval of data from the ACM of the Charger at the scene of the collision was a search and seizure that implicates the Fourth Amendment. In pertinent part, the Fourth Amendment provides that "[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated[.]" U.S. Const. Amend. IV. The State argued in the trial court and the Court of Appeals that the retrieval of data was not a search and seizure at all because Mobley had no reasonable expectation of privacy in the data. Although the trial court did not decide that question, Judge Mercier agreed that Mobley had no reasonable expectation of privacy in the data, and she concluded as a result that the motion to suppress properly was denied. In this Court, however, the State concedes that its argument below was based on a faulty premise. The State is right to make that concession.

For much of our history, the Fourth Amendment was understood to be concerned only with government trespasses upon the rights of individuals under the common law to be secure in their "persons, houses, papers, and effects." See United States v. Jones, 565 U.S. 400, 406 (II) (A), 132 S.Ct. 945, 181 L.Ed.2d 911 (2012). See also Carpenter v. United States, 585 U.S. –––– (II) (A), 138 S.Ct. 2206, 201 L.Ed.2d 507 (2018). Accordingly, to determine whether a government act amounted to a search, American courts traditionally asked whether the act was to "obtain[ ] information by physically intruding on a constitutionally protected area." Jones, 565 U.S. at 406 n.3 (II) (A), 132 S.Ct. 945. But "[m]ore recently, the [United States Supreme] Court has recognized that property rights are not the sole measure of Fourth Amendment violations." Carpenter, 585 U.S. at –––– (II) (A), 138 S.Ct. 2206 (citation and punctuation omitted). Beginning in Katz v. United States, 389 U.S. 347, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967), the Supreme Court has held in a number of cases that government intrusion into a private sphere marked by a "reasonable expectation of privacy" generally qualifies as a search and, therefore, implicates the Fourth Amendment, irrespective of whether the intrusion amounts to a trespass upon private rights under the common law. See Carpenter, 585 U.S. at –––– (II) (A), 138 S.Ct. 2206. See also Smith v. Maryland, 442 U.S. 735, 739 (II) (A), 99 S.Ct. 2577, 61 L.Ed.2d 220 (1979) ; Katz, 389 U.S. at 360-361, 88 S.Ct. 507 (Harlan, J., concurring).

In this case, the State pressed an argument in the trial court and Court of Appeals premised on the misguided notion that "reasonable expectations of privacy" have supplanted private rights under the common law as the sole standard by which we determine whether a government act amounts to a search. But as the United States Supreme Court has made perfectly clear, "the Katz reasonable-expectation-of-privacy test has been added to , not substituted for , the common-law trespassory test." Jones, 565 U.S. at 409 (II) (A), 132 S.Ct. 945 (emphasis in original). See also id. at 414, 132 S.Ct. 945 (Sotomayor, J., concurring) ("Katz's reasonable-expectation-of-privacy test augmented, but did not displace or diminish, the common-law trespassory test that preceded it."). If either standard is satisfied, the government act in question generally will amount to a search that implicates the Fourth Amendment. See id. at 409 (II) (A), 132 S.Ct. 945.

Although Mobley disputes the idea that he had no reasonable expectation of privacy in the data retrieved from the ACM on the Charger, we find it unnecessary to resolve that question. To retrieve the data, Investigator Hatcher entered the passenger compartment of the Charger and connected a CDR device with the ACM by way of an onboard data port. A personal motor vehicle is plainly among the "effects" with which the Fourth Amendment—as it historically was understood—is concerned, see United States v. Chadwick, 433 U.S. 1, 12, 97 S.Ct. 2476, 53 L.Ed.2d 538 (1977), and a physical intrusion into a personal motor vehicle for the purpose of obtaining information for a law enforcement investigation generally is a search for purposes of the Fourth Amendment under the traditional common law trespass standard. See Jones, 565 U.S. at 404 (II) (A), 132 S.Ct. 945 (installation of tracking device on private vehicle and subsequent use of device to monitor vehicle movements is a search). See also Florida v. Jardines, 569 U.S. 1, 5 (II), 133 S.Ct. 1409, 185 L.Ed.2d 495 (2013). The retrieval of data without a warrant at the scene of the collision was a search and seizure that implicates the Fourth Amendment, regardless of any reasonable expectations of privacy.

3. We next consider whether the retrieval of data was an unreasonable search and seizure forbidden by the Fourth Amendment, and we conclude that it was. The Fourth Amendment evinces a "strong preference for searches conducted pursuant to a warrant." Illinois v. Gates, 462 U.S. 213, 236 (III), 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983). Indeed, the constitutional preference for warrants is so strong that searches and seizures without a warrant "are per se unreasonable under the Fourth Amendment—subject only to a few specifically established and well-delineated exceptions." State v. Slaughter, 252 Ga. 435, 436, 315 S.E.2d 865 (1984) (citation and punctuation omitted). See also Davis v. State, 262 Ga. 578, 580 (1), 422 S.E.2d 546 (1992). Here, Investigator Hatcher retrieved the data from the ACM on the Charger at the scene of the collision without a warrant, and the State has failed to identify any recognized exception to the warrant requirement that is applicable to the facts that are established in the record. Accordingly, the retrieval of data from the ACM in the Charger at the scene of the crash without a warrant was an unreasonable search and seizure that violated the Fourth Amendment.

4. We turn now to the remedy for this violation of the Fourth Amendment. In a long line of decisions beginning with Weeks v. United States, 232 U.S. 383, 34 S.Ct. 341, 58 L.Ed. 652 (1914), the United States Supreme Court has developed and refined an exclusionary rule as the federal constitutional remedy for Fourth Amendment violations. Although applicable at first only in federal courts, this exclusionary rule was made applicable in criminal proceedings in the state courts by the decision in Mapp v. Ohio, 367 U.S. 643, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961).

"When evidence is obtained in violation of the Fourth Amendment, the judicially developed exclusionary rule usually precludes its use in a criminal proceeding against the victim of the illegal search and seizure." Illinois v. Krull, 480 U.S. 340, 347 (II) (A), 107 S.Ct. 1160, 94 L.Ed.2d 364 (1987) (citations omitted). "The purpose of the exclusionary rule is not to redress the injury to the privacy of the search victim," however, but instead "to deter future unlawful police conduct and thereby effectuate the guarantee of the Fourth Amendment against unreasonable searches and seizures." United States v. Calandra, 414 U.S. 338, 347 (III), 94 S.Ct. 613, 38 L.Ed.2d 561 (1974). Consequently, the judicially developed exclusionary rule has been limited to "those situations in which its remedial purpose is effectively advanced," Krull, 480 U.S. at 347 (II) (A), 107 S.Ct. 1160, and the courts have identified a number of exceptions to the usual rule of exclusion. At the urging of the State, the trial court and two judges of the Court of Appeals concluded that one such exception—the inevitable discovery exception—applies here and would allow the admission into evidence of the data retrieved from the Charger at the scene of the collision, even if its retrieval violated the Fourth Amendment. Mobley says that this conclusion was error.

(a) Before we address whether the judges below were right to conclude that the inevitable discovery exception applies on the facts of this case, we must consider a threshold question. Mobley contends that OCGA § 17-5-30 is a statutory exclusionary rule that—unlike its federal counterpart, which developed and has been refined judicially—admits of no exceptions. According to Mobley, OCGA § 17-5-30 categorically precludes the recognition in Georgia of any exception to the exclusionary rule, and in support of this argument, he relies principally on our decision in Gary v. State, 262 Ga. 573, 422 S.E.2d 426 (1992). And because the inevitable discovery exception is not cognizable in Georgia, Mobley says, we need not decide whether the facts of this case fit within the exception. For the reasons that follow, we are unpersuaded.

As we have explained before, "[w]hen we consider the meaning of a statute, we must presume that the General Assembly meant what it said and said what it meant." Deal v. Coleman, 294 Ga. 170, 172 (1) (a), 751 S.E.2d 337 (2013) (citation and punctuation omitted). "To that end, we must afford the statutory text its plain and ordinary meaning, we must view the statutory text in the context in which it appears, and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would." Id. at 172-173 (1) (a), 751 S.E.2d 337 (citations and punctuation omitted). "The common and customary usages of the words are important, but so is their context." Zaldivar v. Prickett, 297 Ga. 589, 591 (1), 774 S.E.2d 688 (2015) (citation and punctuation omitted). "For context, we may look to other provisions of the same statute, the structure and history of the whole statute, and the other law—constitutional, statutory, and common law alike—that forms the legal background of the statutory provision in question." May v. State, 295 Ga. 388, 391-392, 761 S.E.2d 38 (2014) (citations omitted). Our consideration of OCGA § 17-5-30 begins with a brief discussion of the legal context in which the statute was adopted.

Before Mapp, there was no exclusionary rule in Georgia courts for unlawful searches and seizures. As early as 1897, this Court squarely rejected an exclusionary rule as a matter of state law in Williams v. State, 100 Ga. 511, 521, 28 S.E. 624 (1897), a decision that we reaffirmed in Calhoun v. State, 144 Ga. 679, 682, 87 S.E. 893 (1916). Although Georgia law provided other remedies for unlawful searches and seizures, the exclusion of evidence in criminal proceedings was not among them. After Mapp was decided, the Georgia courts promptly acknowledged the federal exclusionary rule. See, e.g., Raif v. State, 109 Ga. App. 354, 361 (1), 136 S.E.2d 169 (1964). Our laws of criminal procedure, however, were not designed to facilitate the application of such a rule. In particular, the trial courts in Georgia had no procedural mechanism by which they properly could entertain and resolve a motion to suppress evidence obtained in violation of the Fourth Amendment prior to trial. See generally Donald E. Wilkes, Jr., "A Most Deplorable Paradox": Admitting Illegally Obtained Evidence in Georgia , 11 GA. L. REV. 105, 130-131 (1976). See also J. Robert Sparks, Search and Seizure , 1 GA. ST. B.J. 427, 429 (1965).

Five years after Mapp, the General Assembly enacted the Search and Seizure Act of 1966, "[a]n Act to provide procedures for searches and seizures and for suppression of evidence illegally seized." Ga. L. 1966, p. 567. Section 13 of the Act—now codified in the Criminal Procedure Code as OCGA § 17-5-30 —established a procedure for the filing, consideration, and resolution of motions to suppress. In pertinent part, it provides:

(a) A defendant aggrieved by an unlawful search and seizure may move the court for the return of property, the possession of which is not otherwise unlawful, and to suppress as evidence anything so obtained on the grounds that:

(1) The search and seizure without a warrant was illegal; or

(2) The search and seizure with a warrant was illegal because the warrant is insufficient on its face, there was not probable cause for the issuance of the warrant, or the warrant was illegally executed.

(b) The motion shall be in writing and state facts showing that the search and seizure were unlawful. The judge shall receive evidence out of the presence of the jury on any issue of fact necessary to determine the motion; the burden of proving that the search and seizure were lawful shall be on the state. If the motion is granted the property shall be restored, unless otherwise subject to lawful detention, and it shall not be admissible in evidence against the movant in any trial.

The text of OCGA § 17-5-30 was borrowed substantially from Federal Rule of Criminal Procedure 41 (e), something of which our Court of Appeals took notice shortly after the enactment of the statute. See Thomas v. State, 118 Ga. App. 359, 360 (2), 163 S.E.2d 850 (1968). And that version of Rule 41 (e) was understood to be "no broader than the constitutional [exclusionary] rule" and not to amount to "a statutory expansion of the exclusionary rule." Calandra, 414 U.S. at 348 n.6 (III), 94 S.Ct. 613 (citing Alderman v. United States, 394 U.S. 165, 89 S.Ct. 961, 22 L.Ed.2d 176 (1969), and Jones v. United States, 362 U.S. 257, 80 S.Ct. 725, 4 L.Ed.2d 697 (1960) ).

Mobley urges that OCGA § 17-5-30 should be understood to absolutely and without exception require the suppression of any evidence obtained by way of any search and seizure that is described in paragraph (a) (1) or (a) (2) of the statute—a search without a warrant that is unlawful for any reason, a search pursuant to a warrant that is unlawful because "the warrant is insufficient on its face," a search pursuant to a warrant that is unlawful because "there was not probable cause for the issuance of the warrant," or a search pursuant to a warrant that is "illegally executed"—irrespective of whether the federal constitutional exclusionary rule would require its suppression. Read without regard to its context, perhaps that would be the most reasonable understanding of OCGA § 17-5-30, although it is not the only way in which the statute reasonably could be understood. But we do not endeavor to give meaning to statutes without consideration of their context. See Zaldivar, 297 Ga. at 591 (1), 774 S.E.2d 688.

The legal context of OCGA § 17-5-30 points to a different understanding. The Georgia courts consistently rejected an exclusionary rule for violations of the Fourth Amendment until Mapp left our courts with no choice but to recognize such a rule. The existing laws of criminal procedure, however, made no provision for a procedure by which the exclusionary rule could be applied before trial, a problem that was widely acknowledged in the contemporary legal scholarship. Within a short time, the General Assembly acted to adopt a law "to provide procedures for search and seizures and for the suppression of evidence," Ga. L. 1966, p. 567 (emphasis supplied), and in particular, to provide "procedures ... for the suppression of evidence," the General Assembly borrowed from Federal Rule of Evidence 41 (e), a rule that was understood to confer no greater right to exclude evidence than the constitutional exclusionary rule. This context leads to the conclusion that OCGA § 17-5-30 is most naturally and reasonably understood to be merely a procedural statute, establishing a mechanism for the application of an exclusionary rule, the scope and limits of which must be ascertained from the decisional law by which it developed.

Against this understanding of the statute, however, stands our decision in Gary. In that case, we were confronted with evidence obtained by way of a search pursuant to a warrant that was issued without probable cause. See Gary, 262 Ga. at 577, 422 S.E.2d 426. The Court of Appeals had held that the evidence nevertheless was admissible under an exception to the exclusionary rule for warrants issued without probable cause but executed by officers relying in good faith on the validity of the warrants, an exception that the United States Supreme Court had adopted in United States v. Leon, 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984). See Gary, 262 Ga. at 574, 422 S.E.2d 426.

In Gary, we issued a writ of certiorari and reversed, holding that recognition of the Leon exception is foreclosed in Georgia by OCGA § 17-5-30. We began our analysis of the statute with the notion that it was enacted " ‘to provide for searches and seizures and for suppression of evidence illegally seized,’ " id., and we then said (without further analysis) that the adoption of the statute reflected the determination of the General Assembly to "impose greater requirements upon its law enforcement officers than that required by the United States Constitution, as interpreted by the U.S. Supreme Court." Id. at 574-575, 422 S.E.2d 426. After reciting the relevant (in the context of that case) provisions of OCGA § 17-5-30 (a) (2) and (b), we summarily concluded: " OCGA § 17-5-30 is the legislature's unequivocal expression of its desire that evidence seized by means of a warrant that is not supported by probable cause be suppressed." Id. at 575, 422 S.E.2d 426. From this broad understanding of the statute, we then reasoned that the statute more specifically forecloses the application in Georgia of the Leon exception. Id. at 575-576, 422 S.E.2d 426. We gave no consideration in Gary to the legal context of OCGA § 17-5-30, including the background law of Georgia at the time of its enactment and the understanding of Rule 41 (e), from which its provisions were substantially borrowed. Because Gary failed to consider this important context, we conclude that its broader reasoning is unsound, and its understanding of OCGA § 17-5-30 is simply incorrect.

The question, therefore, is what to do with Gary. In the nearly 30 years since that decision, this Court has relied on it in only three cases to reject an exception to the exclusionary rule, all involving claims that evidence obtained by officers relying in good faith on the validity of a search warrant should be admitted, notwithstanding the unlawfulness of the search and seizure. See Beck v. State, 283 Ga. 352, 353 (1), 658 S.E.2d 577 (2008) (officers relied on search warrant issued by person not authorized to issue warrants); Harper v. State, 283 Ga. 102, 107 (2), 657 S.E.2d 213 (2008) (officers relied on search warrant issued without probable cause); Miley v. State, 279 Ga. 420, 422, 614 S.E.2d 744 (2005) (officers relied on search warrant issued without probable cause). We never have extended Gary and its construction of OCGA § 17-5-30 to foreclose application of any other established exception to the exclusionary rule. To the contrary, we and the Court of Appeals have applied other exceptions in a number of cases without mention of Gary. See, e.g., Teal v. State, 282 Ga. 319, 325 (2), 647 S.E.2d 15 (2007) (inevitable discovery exception); Taylor v. State, 274 Ga. 269, 274-275 (3), 553 S.E.2d 598 (2001) (inevitable discovery exception); Stephens v. State, 346 Ga. App. 686, 691-693 (2), 816 S.E.2d 748 (2018) (independent source exception); Pinkney v. State, 332 Ga. App. 727, 731 (2), 774 S.E.2d 770 (2015) (independent source exception); Ansley v. State, 325 Ga. App. 226, 231 (1) (b), 750 S.E.2d 484 (2013) (independent source exception); Schweitzer v. State, 319 Ga. App. 837, 840, 738 S.E.2d 669 (2013) (inevitable discovery exception); Williams v. State, 308 Ga. App. 464, 468 (2), 708 S.E.2d 32 (2011) (inevitable discovery exception); Cunningham v. State, 284 Ga. App. 739, 742, 644 S.E.2d 878 (2007) (inevitable discovery exception). And before this case, no case appears to have ever suggested that OCGA § 17-5-30 could be understood to foreclose the inevitable discovery or any other exception, although we must concede in fairness to Mobley that a logical extension of the broad reasoning of Gary—that OCGA § 17-5-30 is a statutory exclusionary rule that admits of no exceptions—would seemingly lead to that conclusion.

Gary involved the admission of evidence obtained by way of a search conducted by officers relying in good faith on the validity of a search warrant issued without probable cause, and the three cases in which we have relied on Gary all involved officers relying in good faith on the validity of search warrants. Whether the holdings of Gary and its progeny should be squarely overruled is a question that would require a consideration of the doctrine of stare decisis, see State v. Jackson, 287 Ga. 646, 658 (5), 697 S.E.2d 757 (2010), but that is not a question that we must answer to resolve this case. This case does not involve good faith reliance on the validity of a search warrant, and we never have relied on the broader reasoning of Gary to foreclose consideration of an exception to the exclusionary rule in any other context, including with respect to the inevitable discovery exception. Today, we disavow the unsound reasoning of Gary, hold that it does not extend to any context other than the reliance of an officer in good faith upon the validity of a search warrant, and conclude that, in all other contexts, OCGA § 17-5-30 means what it most naturally and reasonably is understood in context to mean—it establishes a procedure for applying the exclusionary rule but does not itself require the suppression of any evidence. It does not, therefore, categorically foreclose the application of any other exception to the exclusionary rule.

(b) We turn at last to consider whether the inevitable discovery exception applies on the facts of this case, and we conclude that it does not. This Court has explained that, for the inevitable discovery exception to apply, "there must be a reasonable probability that the evidence in question would have been discovered by lawful means, and the prosecution must demonstrate that the lawful means which made discovery inevitable were possessed by the police and were being actively pursued prior to the occurrence of the illegal conduct." Taylor v. State, 274 Ga. 269, 274-275 (3), 553 S.E.2d 598 (2001) (citation and punctuation omitted), disapproved in part on other grounds in State v. Chulpayev, 296 Ga. 764, 783 (3) (b), 770 S.E.2d 808 (2015). See also Teal v. State, 282 Ga. 319, 325 (2), 647 S.E.2d 15 (2007). In this case, the State urges that, if Investigator Hatcher had not retrieved the ACM data from the Charger at the scene of the collision, the data would have been discovered in any event pursuant to a search warrant, as illustrated by the search warrant that Investigator Thornton obtained on the day after the crash.

The State is right that a search warrant issued upon probable cause may be a "lawful means" to discover evidence. See Teal, 282 Ga. at 326 (2), 647 S.E.2d 15. See also United States v. Delva, 922 F.3d 1228, 1245-1246 (IV) (B) (11th Cir. 2019). And for the purposes of this opinion, we accept that the investigating officers had the requisite probable cause to obtain a warrant even before Investigator Hatcher retrieved the data from the Charger at the scene of the collision. The record in this case, however, does not show that the officers were "actively pursu[ing]" a search warrant at the time Investigator Hatcher retrieved the data without a warrant. Absent proof that the officers were actively pursuing a warrant at that point in time, the mere fact that Investigator Thornton actually obtained a warrant on the following day is not enough to bring this case within the inevitable discovery exception. See United States v. Satterfield, 743 F.2d 827, 846 (IV) (B) (11th Cir. 1984). Cf. Delva, 922 F.3d at 1245 (IV) (B) ("Here, in addition to obtaining a warrant to search the Mercedes later that same day, the Agents were actively pursuing that warrant before they initially searched the Mercedes." (Emphasis supplied)). Indeed, "[b]ecause a valid search warrant nearly always can be obtained after a search has occurred," allowing law enforcement to use a warrant from after-the-fact to justify an earlier search would threaten to vitiate the warrant requirement. Satterfield, 743 F.2d at 846 (IV) (B). Cf. United States v. Johnson, 777 F.3d 1270, 1276 (III) (A) (11th Cir. 2015).

There is no evidence that any of the investigating officers applied for a warrant, were preparing an application for a warrant, or even were contemplating a warrant before Investigator Hatcher retrieved the data. Nor is there evidence that the Henry County Police Department has a policy, standard operating procedure, or consistent practice that leads officers to always or even routinely obtain search warrants for ACM data in the investigation of fatality crashes. See Davis, 262 Ga. at 583 (4), 422 S.E.2d 546 ("The state has not shown that a warrant would have been sought as part of the inevitable, routine procedure of the Douglas County Sheriff's Department [in these circumstances]."). To the contrary, the officers in this case testified that the most common practice in such investigations is to retrieve ACM data at the scene of a crash without a warrant. Not one of the officers suggested that they usually obtain warrants in cases like this one.

In its order denying the motion to suppress, the trial court concluded that an application for a warrant was inevitable, a conclusion based entirely on its finding that Investigator Thornton "always seeks such a warrant in accidents involving fatalities." Investigator Thornton, however, was off duty on the day of the collision, and there is no evidence that his involvement in the case was even contemplated until the next day. That a particular officer always seeks a search warrant in similar circumstances cannot logically show that a warrant was inevitable at a point in time prior to that officer becoming involved in the case. Equally important, Investigator Thornton did not actually testify that he always obtains warrants in fatality crash investigations. To the contrary, he said that he always retrieves ACM data in such investigations, most commonly without a warrant at the scene of the crash. Investigator Thornton testified that, if ACM data could not be retrieved at the scene, he would seek a warrant, but that hardly suggests that warrants always or usually are sought, considering that the routine practice is to retrieve data at the scene without a warrant. The finding of the trial court that Investigator Thornton always seeks a warrant in cases like this one is clearly erroneous. See State v. Rosenbaum, 305 Ga. 442, 449 (2), 826 S.E.2d 18 (2019) (when this Court reviews a ruling on a motion to suppress, we defer to the factual findings of the trial court unless clearly erroneous).

The State has failed to lay an evidentiary foundation for the application of the inevitable discovery exception in this case. And the State has failed to identify any other established exception to the exclusionary rule that is applicable to the facts as shown by the record in this case. Accordingly, the usual rule of exclusion holds, and the trial court should have granted the motion to suppress. The judgment of the Court of Appeals, affirming the decision of the trial court, is reversed.

Judgment reversed.

All the Justices concur, except Melton, C.J., who concurs in judgment only.