The following excerpt is from Ramsden v. U.S., 2 F.3d 322 (9th Cir. 1993):
2 The Government cites Washington v. Chrisman, 455 U.S. 1, 102 S.Ct. 812, 70 L.Ed.2d 778 (1982), for the proposition that police officers can make plain view seizures of contraband after they accompany an arrestee into a room after making an arrest in a hallway. This case and its progeny are clearly distinguishable because no contraband was seized in the instant case and many of the documents were not in plain view.
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