In what circumstances have courts found that the total seizure of "contraband" during a search was lawful?

(4) The trial court held that the total seizure was lawful in reliance on cases (such as Skelton v. Superior Court (1969) 1 Cal.3d 144, 81 Cal.Rptr. 613, 460 P.2d 485) which allow the seizure of 'contraband' legitimately seen by officers while conducting a lawful search for other items. But we know of no authority that extends that rule to the seizure of matter which lies within the special protection of rules developed under the First Amendment. In fact, the cases which we have found hold that, where an item is sought which may turn out to be protected by the First Amendment, no seizure may be made without the express authority of a magistrate. ¹⁰

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