What is the limitation on probable cause under the search warrant?

We now turn to the final limitation which requires that the officer have probable cause to believe that the item seized was of a criminal nature and constituted evidence of a crime. Arizona v. Hicks, 480 U.S. at 326, 107 S.Ct. at 1153; Texas v. Brown, 460 U.S. at 741-42, 103 S.Ct. at 1542-43. Of the three plain view conditions this is the only one that presents a close question in this appeal. Probable cause is a flexible, common sense standard that "merely requires that the facts available to the officers would 'warrant a man of reasonable caution in the belief' that certain items may be contraband ... or useful as evidence of a crime; it does not

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