This analysis examines the Court's interpretation of the plain view doctrine and concludes that the Court properly held that the plain touch doctrine is analogous to the plain view doctrine. The author argues, however, that the Court provided a vague outline of the requirements of this newly recognized exception to the warrant requirement. The Court wavered between two different standards of certainty, referring to both "probable cause" and "immediately apparent." This article argues that probable cause is the proper standard of certainty. Additionally, the Court required that the officer have lawful access to the object before seizing it, without explaining how this requirement functions in the plain touch context. The author further argues that the Court improperly upheld the lower court's reversal. The Court should have satisfied any doubt about the scope of the search by remanding the case for further proceedings. 202 footnotes