As technology becomes ubiquitous in the work of criminals, courts continue to struggle with how to apply the Fourth Amendment to searches of electronic devices. One of the more vexing issues is how the “plain view” exception to the warrant requirement applies to such searches. A decision from the Second Circuit last month, in U.S. v. Galpin, demonstrates the difficulty of devising a sound approach in the digital age, where a single hard drive may contain information that, in the past, would fill warehouses. The decision also highlights the difficulty in enforcing a rigid approach. This means judges are likely to be called on to exercise even more than the usual amount of judgment when examining the methods that law enforcement uses to search for digital evidence in a particular case.