Riley v. California
Citation: 573 U.S. 373 (2014)
Facts
David Riley was stopped for a traffic violation and arrested. An officer seized his smartphone and searched it without a warrant, finding evidence linking Riley to gang activity and a shooting. In a companion case, Brima Wurie’s call log on a flip phone was searched incident to arrest, leading to evidence of drug dealing. Both defendants moved to suppress.
Issue
Whether police may, without a warrant, search the digital contents of a cell phone seized from a person who has been lawfully arrested.
Holding
The Supreme Court unanimously held that police generally must obtain a warrant before searching a cell phone seized incident to arrest. The two traditional rationales for the search-incident exception — officer safety and evidence preservation — do not apply to the data on a phone.
Rule
Cell phones cannot be searched incident to arrest without a warrant. The immense storage capacity and personal nature of digital data on modern smartphones places such searches outside the rationale of the search-incident-to-arrest exception.
Significance
Riley is the defining case on digital privacy and the Fourth Amendment. Chief Justice Roberts’ opinion, acknowledging that “a cell phone search would typically expose to the government far more than the most exhaustive search of a house,” signaled that the Court would not mechanically apply old doctrine to new technology. It is essential reading alongside Carpenter v. United States on digital privacy.