The following excerpt is from U.S. v. Windsor, 28 F.3d 110 (9th Cir. 1994):
Windsor argues that even if the district court found he consented to the search, it should have concluded that the briefcase, in which the police found bags of methamphetamine, was beyond the scope of the search to which he consented. Because he did not make this argument in district court, we review only for plain error. United States v. Dischner, 974 F.2d 1502, 1515 (9th Cir.1992), cert. denied, 113 S.Ct. 1290 (1993).
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