In United States v. Grubbs, 547 U.S. 90, 94-95, 126 S. Ct. 1494, 164 L. Ed. 2d 195 (2006), law-enforcement officers obtained a warrant to search Grubbs' home upon delivery by Post Office officials of a packaged videotape containing child pornography. 547 U.S. at 92. Upon subsequent delivery of the package to Grubbs' wife at home, officers executed the warrant, searched the home, and seized the videotape and other items. Id. at 93. In his criminal case, Grubbs moved to suppress evidence of the seized property, which the district court denied. Id. After Grubbs' conviction, the Ninth Circuit reversed. Id. One issue before the Supreme Court was whether anticipatory search warrants are prohibited by the Fourth Amendment. Id. at 94. Grubbs asserted that such warrants violate the probable-cause requirement, as at the time of issuance, probable cause does not exist that the property sought is at the location specified in the warrant. Id. at 94-95. The Court disagreed, pointing out that in a sense all warrants are anticipatory as the pertinent probable-cause inquiry is whether evidence will be found when the search is conducted. Id. at 95. One example given by the Court was in the context of electronic surveillance. Id. The Court related that when police request a warrant to tap a telephone line, "they do so based on the probability that, during the course of the surveillance, the subject will use the phone to engage in crime-related conversations." Id. The Court concluded that anticipatory warrants are no different than ordinary warrants and require the issuing court "to determine: (1) that it is now probable that; (2) contraband, evidence of a crime, or a fugitive will be on the described premises; (3) when the warrant is executed." Id. at 96.