California, United States of America
The following excerpt is from People v. Frank, 214 Cal.Rptr. 801, 38 Cal.3d 711, 700 P.2d 415 (Cal. 1985):
The doctrine reflected in these cases is not, however, without its proper limitations. In People v. Haas (1976) 55 App.Div.2d 683, 390 N.Y.S.2d 202, for example, the court--after concluding that there was probable cause to support a warrant's authorization to search for marijuana, but not its additional authorization to search for stolen goods--refused to uphold the seizure of the stolen goods, explaining: "The items seized, i.e., a passport, an envelope containing coins, certain documents, etc., are not the type of items in which a searcher for marijuana could reasonably expect to find marijuana, especially in view of the fact that the search warrant authorized a [700 P.2d 446] search for 'Marijuana Plants.' [Citation.]
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