California, United States of America
The following excerpt is from Griffin v. Superior Court, 103 Cal.Rptr. 379, 26 Cal.App.3d 672 (Cal. App. 1972):
In People v. Mayen (1922) 188 Cal. 237, 240, 242, 205 P. 435, 437, the court held invalid a warrant directing the seizure of "certain personal property used as a means of committing a public offense, to wit, attempted
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