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In Coolidge v. New Hampshire, 403 U. S. 443 (1971), the court said that, in certain circumstances, a warrantless seizure by police of an item that comes within plain view during their lawful search of a private area may be reasonable under the Fourth Amendment. See id. at 403 U. S. 465-471 (plurality opinion); id. at 465 U. S. 505-506 (Black, J., concurring and dissenting); id. at 465 U. S. 521-522 (WHITE, J., concurring and dissenting). Can the 'plain view' doctrine be invoked when the police have less than probable cause to believe that the item in question is evidence of a crime or is contraband? 

'It is well established that, under certain circumstances, the police may seize evidence in plain view without a warrant,' Coolidge v. New Hampshire, 403 U.S. at 403 U. S. 465 (plurality opinion) (emphasis added). Those circumstances include situations '[w]here the initial intrusion that brings the police within plain view of such [evidence] is supported . . . by one of the recognized exceptions to the warrant requirement,' ibid., such as exigent circumstances. Probable cause is required to involved the plain view doctrine. To say otherwise ...

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