content: Mapp V. Ohio, while an important case, doesn't really discuss plain view like this does (iirc, i'm no constitutional lawyer, and my knowledge of less recent landmark cases is a touch fuzzy), it was more used to establish that evidence obtained through illegal searches cannot be used in court. So this is most certainly progress, (Though I would argue that a phone wallpaper, if visible from the lockscreen COULD be plain view on anything but a flip phone like what was used here, nothing beyond it should be) if only a small amount.