In Anderson v. State, the supreme court held a police officer validly seized the defendant’s clothing without a warrant because the officer saw the clothing in open view and had probable cause to believe the clothing was evidence of a crime. In the course of breaking into a home, Anderson injured the home’s occupants, and one of them also shot him. At a local hospital where Anderson went for treatment, a police officer, who was there to interview victims of the crime, stayed with Anderson as doctors treated him because of the blood on his shirt from his gunshot wound. After being informed by another officer that Anderson was a suspect, the first officer seized Anderson’s clothing. The superior court found the plain view doctrine justified the seizure, and a jury convicted Anderson of assault, for which he was sentenced to 20 years in prison. On appeal, Anderson argued the superior court erred by failing to suppress the warrantless seizure of his clothing. The supreme court affirmed the no-suppression ruling after reviewing the two types of plain view doctrines. Focusing on the second type of plain view doctrine, which the supreme court distinguished by calling it open view, the supreme court explained probable cause that an object is evidence of a crime justifies a warrantless seizure if no other Fourth Amendment intrusion is required. Given the blood stains on Anderson’s clothes provided probable cause to believe they were connected to the home invasion, the officer was justified in seizing the clothes from a hospital room where she was lawfully present. Affirming the lower court, the supreme court held a police officer validly seized the defendant’s clothing without a warrant because the officer saw the clothing in open view and had probable cause to believe the clothing was evidence of a crime.
 444 P.3d 239 (Alaska 2019).