How has the exclusionary rule been interpreted in the context of past-down searches?

In its original determination the trial court found that but for the past-down no contraband would have been discovered. Similarly, but for the misapplication of Simon the arrest predicated on the unlawful pat-down and the search incident to that arrest would have come within the purview of the exclusionary rule and the evidence obtained thereby would have been inadmissible. (People v. Cahan (1955) 44 Cal.2d 434, 282 P.2d 905.) As the illegally seized material was the only evidence against defendant,

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