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Defendant was in a car that was stopped and the police had probable cause. The made her leave her purse behind. When the warrant issued, the purse could be searched because it was with the car, for which there was probable cause. State v. Campbell, 2011 Wash. App. LEXIS 2875 (December 29, 2011), Order Granting Motion to Publish 165 Wn. App. 1021, 2011 Wash. App. LEXIS 2915 (Wash. Ct. App., Dec. 29, 2011):

Circumstances can exist where probable cause may exist for a search of an individual's property even though officers do not have equivalent probable cause that the owner of the property is involved in crime. Cf. Zurcher v. Stanford Daily, 436 U.S. 547, 556-57, 98 S. Ct. 1970, 56 L. Ed. 2d 525 (1978) (Fourth Amendment does not prevent issuance of a warrant to search property simply because the owner or possessor is not reasonably suspected of criminal involvement); see also 2 Wayne R. Lafave, Search and Seizure: A Treatise on the Fourth Amendment § 4.10(b) at 747-48 (4th ed. 2004) (distinguishing entitlement to search a visitor's belongings where police have grounds to believe items sought in the warrant might be concealed there). Both Worth and Hill implicitly recognize that personal property belonging to someone other than the owner of premises can be subject to a warrant for a premises search where probable cause exists and the scope of a warrant is accordingly broad: Worth's holding depends on its reasoning that no probable cause brought Worth's purse within the scope of the warrant. Hill's holding that “generally officers have no authority under a premises warrant to search personal effects an individual is wearing or holding” implies that sometimes they do. 123 Wn.2d at 644 (emphasis added).

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The search warrant was for marijuana, cocaine, and paraphernalia, but there was only probable cause for marijuana, so the remainder is excised from the warrant. Nevertheless, the police were properly in defendant’s home on the warrant, and they could seize other drugs in plain view and as inevitable discovery. Commonwealth v. Anderson, 2012 PA Super 65, 2012 Pa. Super. LEXIS 103 (March 19, 2012).

Two people lived at defendant’s house besides him, and one of the others granted consent. There was no reason to doubt their authority to consent. Smallfoot v. State, 2012 WY 39, 2012 Wyo. LEXIS 41 (March 16, 2012).*

The district judge does not need to say that a de novo review was done because it is presumed that it was. Defendant was removed from the house and another officer stayed behind to ask about others in the house, and then a plain view occurred. It was reasonable. United States v. Ginn, 2012 U.S. App. LEXIS 5627 (8th Cir. March 19, 2012) (unpublished).*

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