Horton v.California (1990)is the case that removed the requirement of inadvertence from the plain view doctrine.

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The Horton v. California (1990) case held that the inadvertence requirement was not an essential part of the plain view doctrine. Therefore, law enforcement officers can conduct a warrantless search and seize evidence in plain view as long as they have a lawful right of access to the object, the discovery of the evidence is inadvertent, and the evidence's incriminating character is immediately apparent to them.

Horton VCalifornia (1990)is the Case That Removed the Requirement of Inadvertence