be taken to imply that an unduly high degree of certainty as to the incriminatory character of evidence is necessary for an application of the ‘plain view5 doctrine.”). Disputes over its meaning arise primarily in cases in which the police have had to conduct additional examinations in order to determine the import of an object. See Horton, 496 U.S. at 136-37, 110 S.Ct. at 2307-08; United States v. Garces, 133 F.3d 70, 75-76 (D.C.Cir.1998). It is clear that the requirement is satisfied, however, where the officers had “probable cause” to believe that an item was incriminating “without the benefit of information from any unlawful search or seizure.” Garces, 133 F.3d at 75. And because the touchstone is probable cause, see United States v. Washington, 12 F.3d 1128, 1133 (D.C.Cir.1994) (<HOLDING>), a “seizing officer need not ‘know’ or have an
holding that where other evidence established probable cause to believe that the defendant possessed controlled substances investigating officers had probable cause to search the defendants purse for similar evidence holding that the purpose of a preliminary examination is to determine whether there is probable cause to believe that a crime was committed and whether there is probable cause to believe that the defendant committed it holding that the officers examination revealed that there was probable cause to believe that the property was stolen holding that the police officers had probable cause to make a warrantless entry holding that the incriminating nature of an item was immediately apparent where the police officers had probable cause to believe that it contained evidence of a crime