## Facts

- David Leon Riley was stopped for expired registration; officers discovered his license was suspended, impounded the car, and conducted an inventory search that uncovered firearms.
- Riley was arrested; officers seized a smartphone from his pocket and, without a warrant, accessed data that suggested gang affiliation.
- At the station, a detective further searched the phone’s photos and videos; the phone data helped link Riley to a prior shooting and supported a gang-enhancement allegation.
- Brima Wurie was arrested after police observed an apparent drug transaction; officers seized a flip phone from his person.
- Without a warrant, officers accessed the phone’s call log after seeing repeated calls from “my house,” traced the number to an apartment, and later obtained a warrant to search the residence.
- The residential search yielded drugs, a firearm, ammunition, and cash, forming the basis for federal charges.

## Issues

1. Whether the Fourth Amendment permits police, under the search-incident-to-arrest exception, to search digital information on a cell phone seized from a lawfully arrested person without a warrant.

## Decision

- The Supreme Court held unanimously that police generally may not, without a warrant, search digital information on a cell phone seized incident to arrest.
- The search-incident-to-arrest exception does not categorically justify accessing a phone’s digital contents.
- Riley: state appellate judgment reversed and remanded.
- Wurie: First Circuit judgment suppressing the phone evidence affirmed.

## Legal Principles

- Searches undertaken to discover evidence are generally reasonable only with a judicial warrant; warrantless searches are valid only within a recognized exception.
- Search incident to arrest is justified by officer-safety and evidence-preservation rationales limited to the arrestee’s person and the area within immediate control.
- Digital data on a phone does not itself threaten officer safety; officers may physically secure the device but may not routinely search its contents without a warrant.
- General concerns about remote wiping or encryption do not justify a categorical rule permitting warrantless phone-data searches; officers may secure the device while seeking a warrant.
- Cell phones differ from physical containers due to the volume, sensitivity, and long-term aggregation of personal information they can store; extending categorical container-search rules to digital data would impose materially greater privacy costs.
- Exigent circumstances and other established exceptions may still permit a warrantless search of a particular phone based on case-specific facts.

## Conclusion

The Court required a warrant in the ordinary case before police may search digital information on a cell phone seized from an arrestee, limiting search-incident-to-arrest doctrine in light of the distinctive privacy interests implicated by modern digital storage while preserving emergency and other established exceptions.


Riley v. California, 134 S. Ct. 2473 (2014)