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During a pat down or frisk a police officer may seize any contraband that the officer can immediately discern, by touch but not by manipulation. Most state and federal courts have recognized a so-called “plain-feel” or “plain-touch” corollary to the plain-view doctrine. See United States v. Coleman, 969 F.2d 126, 132 (CA5 1992); United States v. Salazar, 945 F.2d 47, 51 (CA2 1991), cert. denied, 504 U.S. 923 (1992); United States v. Buchannon, 878 F.2d 1065, 1067 (CA8 1989); United States v. Williams, 262 U.S. App. D.C. 112, 119-124, 822 F.2d 1174, 1181-1186 (1987); United States v. Norman, 701 F.2d 295, 297 (CA4), cert. denied, 464 U.S. 820 (1983); People v. Chavers, 33 Cal.3d 462, 471-473, 658 P.2d 96, 102-104 (1983); Dickerson v. State, No. 228, 1993 Del. LEXIS 12, *3-*4 (Jan. 26, 1993); State v. Guy, 172 Wis.2d 86, 101-102, 492 N.W.2d 311, 317-318 (1992).


Some state courts, have rejected such a corollary. See People v. Diaz, 81 N.Y.2d 106, 612 N.E.2d 298 (1993); State v. Collins, 139 Ariz. 434, 435-438, 679 P.2d 80, 81-84 (Ct. App. 1983); People v. McCarty, 11 Ill. App.3d 421, 422, 296 N.E.2d 862, 863 (1973); State v. Rhodes, 788 ...

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