What case established that Plain View Seizures do not need to be inadvertent?

The case that established that plain view seizures do not need to be inadvertent is Horton v. California. This landmark decision clarified that law enforcement officers may seize evidence that is in plain view, even if they were not initially aware that the evidence was present when they entered the location. The Court ruled that the requirement for "inadvertence" does not apply in all circumstances, allowing officers to seize items they are aware of in plain sight as long as they are lawfully present at the location where the evidence isfound, and the incriminating nature of the items is immediately apparent.

This ruling helps define the balance between an individual's Fourth Amendment rights against unlawful search and seizure and the practical realities that law enforcement faces. The clarification has had significant implications in numerous cases since then, shaping how police conduct searches and seizures in the field.