The Open-Ended Warrant

Police purchased two films from Lo-Ji Sales, an adult bookstore in Ellicotville, New York, and determined they were obscene. A Town Justice issued a warrant to search the store for those specific films and for similar obscene material. During a six-hour search, officers and the Town Justice seized 431 films, magazines, and other items. The search was extensive and yielded a large quantity of allegedly obscene material. The Town Justice — an appropriate judicial officer — reviewed the two purchased films, determined they were obscene, and issued a search warrant. A judge made the probable cause determination before the search.