Facts
- Police stopped David Riley for expired registration tags and learned his license was suspended; an inventory search of his impounded car found two firearms, leading to his arrest.
- During a search incident to arrest, an officer seized Riley’s smartphone and accessed information suggesting gang affiliation.
- About two hours later at the station, a detective searched the phone’s digital contents and found photos and videos linking Riley to gang activity and a shooting; prosecutors used this evidence to support serious charges and a gang enhancement.
- In a separate case, police arrested Brima Wurie after observing what they believed to be a street-level drug sale.
- At the station, officers seized Wurie’s flip phone; it repeatedly received calls labeled “my house.”
- Without a warrant, officers opened the phone, accessed the call log, and used the “my house” number to identify Wurie’s residence.
- Police then obtained a warrant to search the apartment and recovered drugs, a firearm, ammunition, and cash; Wurie was convicted of federal drug and firearm offenses.
- Riley’s motion to suppress was denied by California courts under the search-incident-to-arrest doctrine; Wurie’s suppression motion was denied by the district court, but the First Circuit reversed and vacated his convictions.
- The Supreme Court consolidated the cases to resolve whether police may search digital information on a seized cell phone incident to arrest without a warrant.
Issues
- Whether the Fourth Amendment permits police, under the search-incident-to-arrest exception, to search the digital contents of a cell phone seized from an arrestee without a warrant.
- Whether officer-safety and evidence-preservation rationales justify a categorical rule allowing warrantless cell phone data searches incident to arrest.
Decision
- The Court held unanimously that police generally may not, without a warrant, search digital information on a cell phone seized from an arrestee.
- The Court reversed the judgment upholding the warrantless phone search in Riley’s case.
- The Court affirmed the First Circuit’s judgment that the warrantless phone search in Wurie’s case violated the Fourth Amendment.
- The Court stated that, absent another exception such as case-specific exigent circumstances, officers must obtain a warrant before searching a phone’s digital contents.
Legal Principles
- The search-incident-to-arrest doctrine is justified primarily by officer safety and preventing destruction of evidence, but those rationales do not support routine searches of digital data on seized cell phones.
- Digital data on a secured phone cannot itself be used as a weapon, substantially weakening the officer-safety justification for searching the phone’s contents.
- General concerns about remote wiping or encryption do not justify a categorical rule; officers may take reasonable steps to secure a phone and may rely on exigent circumstances when genuinely present.
- Cell phones are not treated as ordinary physical “containers” for incident-to-arrest purposes because their digital storage and access to remote data create qualitatively different and far more extensive privacy intrusions than searches of physical items carried on the person.
- The warrant requirement remains the default rule for evidentiary searches of cell phone contents; exceptions apply only under established, case-specific Fourth Amendment doctrines.
Conclusion
The Court limited the search-incident-to-arrest exception for modern cell phones by requiring police to obtain a warrant, in the ordinary case, before searching digital information on a phone seized from an arrestee, while leaving room for established exceptions such as exigent circumstances.