What is the scope of a search pursuant to a warrant?

The general rule concerning the permissible scope of a search conducted pursuant to a warrant is that "only the property described in the warrant may be seized." (Skelton v. Superior Court (1969) 1 Cal.3d 144, 155, 81 Cal.Rptr. 613, 620, 460 P.2d 485, 492.) However, there is a well-established exception under which the challenged seizures can be held to be lawful. As the court stated in Skelton at page 157, 81 Cal.Rptr. at page 622, 460 P.2d at page 494: "When officers, in the course of a bona fide effort to execute a valid search warrant, discover articles which, although not included in the warrant, are reasonably identifiable as contraband, they may seize them whether they are initially in plain sight or come into plain sight subsequently, as a result of the officers' efforts."