Since the 1967 U.S. Supreme Court's decision in Warden, Maryland Penitentiary v. Hayden, the scope of business records subject to search and seizure has expanded dramatically. Cases such as United States v. Brien (1980) have held that in the instance of probable cause to believe that a business is permeated with fraud, most of all records may be seized if accurately described in the warrant. The zenith of expansive language was reached in the United States v. The Offices Known as 50 State Distributing Co. (1983), in which the ninth circuit court upheld a warrant with generic descriptions of documents and a general 'tail.' A growing minority of courts have adopted a promising approach called 'redaction,' which involves striking from a warrant those severable phrases and clauses that are invalid for lack of probable cause or generality and preserving those severable phrases and clauses that satisfy the fourth amendment. This doctrine is preferable to approaches that use convoluted rationales to find clearly general language adequate to satisfy the fourth amendment. 62 notes.