plain view seizure doctrine (Texas) · Go Syfert
← Texas issues

plain view seizure doctrine in Texas

18 Texas opinions name it 2 courts 2000–2015 0 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Ramos v. Stategreen
texcrimapp · 1996 · cited in 10 Texas opinions naming this issue, 2000–2008
2 sentences

2008“The plain view seizure doctrine requires a *270 two-prong showing: (1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence — that is, there is probable cause to associate the item with criminal activity.” Martinez v. State, 17 S.W.3d 677, 685 (Tex.Crim.App.2000) (citing Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997)).

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

1010
Martinez v. Stategreen
texcrimapp · 2000 · cited in 12 Texas opinions naming this issue, 2003–2012
2 sentences

2012The trial court's fourth finding correctly states that the contraband was found in plain sight, but such a finding does not address the two-pronged showing required by the plain-view seizure doctrine: "(1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence-that is, there is probable cause to associate the item with criminal activity." Martinez v. State, 17 S.W.3d 677, 685 (Tex. Crim.

2012The trial court’s fourth finding correctly states that the contraband was found in plain sight, but such a finding does not address the two-pronged showing required by the plain-view seizure doctrine: “(1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence — that is, there is probable cause to associate the item with criminal activity.” Martinez v. State, 17 S.W.3d 677, 685 (Tex.Crim.App.2000).

512
State v. Haleygreen
texcrimapp · 1991 · cited in 2 Texas opinions naming this issue, 2007–2007
2 sentences

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

2007App. 1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied , 520 U.S. 1198 (1997); State v. Haley , 811 S.W.2d 597, 599 (Tex. Crim.

22
State v. Rossgreen
texcrimapp · 2000 · cited in 2 Texas opinions naming this issue, 2005–2005
2 sentences

2005See State v. Ross , 32 S.W.3d 853, 855-56 (Tex. Crim.

2005See State v. Ross, 32 S.W.3d 853, 855-56 (Tex. Crim.

22
Hudson v. Stategreen
texcrimapp · 1979 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See Hudson v. State, 588 S.W.2d 348, 353 (Tex. Crim.

11
Ramirez v. Stategreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2007–2007
1 sentence

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Triem v. Alaska Bar Ass'n green
scotus · 1997
2 sentences

2008“The plain view seizure doctrine requires a *270 two-prong showing: (1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence — that is, there is probable cause to associate the item with criminal activity.” Martinez v. State, 17 S.W.3d 677, 685 (Tex.Crim.App.2000) (citing Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997)).

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

42000–2008
Steven L. v. Board of Education of Downers Grove Grade School District No. 58 green
scotus · 1997
2 sentences

2008“The plain view seizure doctrine requires a *270 two-prong showing: (1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence — that is, there is probable cause to associate the item with criminal activity.” Martinez v. State, 17 S.W.3d 677, 685 (Tex.Crim.App.2000) (citing Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997)).

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

32000–2008
Guerriero v. Lufthansa German Airlines, Inc. green
scotus · 1997
2 sentences

2008“The plain view seizure doctrine requires a *270 two-prong showing: (1) that law enforcement officials see an item in plain view at a vantage point where they have the right to be, and (2) it is immediately apparent that the item seized constitutes evidence — that is, there is probable cause to associate the item with criminal activity.” Martinez v. State, 17 S.W.3d 677, 685 (Tex.Crim.App.2000) (citing Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997)).

2007See Martinez, 17 S.W.3d at 685 (holding, “We agree with the State that the gun belt was properly obtained [from the appellant’s vehicle] under the plain view seizure doctrine”); Ramos v. State, 934 S.W.2d 358, 365 (Tex.Crim.App.1996) (recognizing items not encompassed within search warrant were nonetheless validly seized pursuant to “plain view seizure” doctrine), cert. denied, 520 U.S. 1198 , 117 S.Ct. 1556 , 137 L.Ed.2d 704 (1997); State v. Haley, 811 S.W.2d 597, 599 (Tex.Crim.App.1991) (holding, “It has been very well settled that items in “plain view” may be seized by *616 law enforcement

32000–2008
Minnesota v. Dickerson green
scotus · 1993
2 sentences

2015Cruse, at *2. 5 Although Cruse is an unpublished opinion and so is not binding precedent, this Court’s reasoning in Cruse is appropriate in this case, as the facts are very similar to those presented here. - 34 - The Court then invoked the plain view seizure doctrine as the rationale for seizing the phone in Cruse, since in light of what the officer knew at the time, there was probable cause to believe the phone contained incriminating evidence: [I]f police are lawfully in a position from which they view an object, if its incriminating character is immediately apparent, and if the officers hav

2015Cruse, at *2. 5 Although Cruse is an unpublished opinion and so is not binding precedent, this Court’s reasoning in Cruse is appropriate in this case, as the facts are very similar to those presented here. - 34 - The Court then invoked the plain view seizure doctrine as the rationale for seizing the phone in Cruse, since in light of what the officer knew at the time, there was probable cause to believe the phone contained incriminating evidence: [I]f police are lawfully in a position from which they view an object, if its incriminating character is immediately apparent, and if the officers hav

12015–2015
Horton v. California green
scotus · 1990
1 sentence

2003Horton v. California , 496 U.S. 128, 136–37 (1990); Ramos v. State , 934 S.W.2d 358, 365 (Tex. Crim .

12003–2003

Where else courts name it

TX 18 (2000–2015) MN 2 (1984–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check