As we have previously reported, courts in recent years have struggled to apply Fourth Amendment principles to searches of electronic devices. One recurring issue is how to limit government searches for evidence of a crime on a device that contains enormous amounts of unrelated private information. Courts are beginning to settle on the application of a practice that has long been used in the worlds of wiretaps and national security investigations: allowing the government access to all of the information but requiring it to “minimize” (i.e., discard) information that is not relevant to the crime. A decision by the United States District Court for the District of Columbia in the case involving the U.S. Navy Yard shooter exemplifies the approach. But it also shows that significant issues remain unresolved, particularly the applicability of the plain view doctrine to electronic searches.