D.N.J.: Plain view supported seizure of records outside scope of search warrant

In a Medicaid fraud document search warrant, some documents found were outside of the scope of the warrant, but they satisfied the plain view doctrine that their potential incriminating nature was immediately apparent and they were found in the course of the search for the other records. United States v. Menendez, 2015 U.S. Dist. LEXIS 129993 (D.N.J. September 28, 2015).*

Defendant was a mere visitor to a hotel room who had no standing. He wasn’t on the guest register, wasn’t spending the night, and didn’t have any belongings in the room. State v. Graves, 2015-Ohio-3936, 2015 Ohio App. LEXIS 3812 (12th Dist. September 28, 2015).*