United States v. George
In United States v. George, 975 F.2d 72 (2d Cir.1992), the warrant authorized a search for several items described with particularity, as well as for "any other evidence relating to the commission of a crime." Id. at 74.
Although the court recognized that this overbroad phrase "effectively granted the executing officers virtually unfettered discretion to seize anything they saw," id. at 75, it found severance appropriate.
In language equally applicable to our own case, the court concluded that "we have before us on this appeal a warrant that is, in part, so broad as to be a general warrant and which, as to that part, no reasonable police officer could suppose otherwise. Yet, we think the warrant in this particular case may be saved ... under the doctrine of severance." Id. at 74.