Riley v. California
573 U.S. 373 (2014)
Rule of Law:
The Fourth Amendment requires police to obtain a warrant before searching the digital information on a cell phone seized from an individual incident to a lawful arrest. The search-incident-to-arrest exception to the warrant requirement does not apply to the digital contents of cell phones.
Facts:
- David Riley was stopped for a traffic violation, which led to his arrest for possession of concealed and loaded firearms found during an inventory search of his impounded car.
- Incident to the arrest, an officer seized Riley's smartphone from his pocket and conducted a brief search of its contents at the scene.
- About two hours later at the police station, a detective conducted a more thorough search of Riley's phone, finding photos and videos that linked him to a prior shooting.
- In a separate case, police observed Brima Wurie appearing to make a drug sale and arrested him.
- At the police station, officers seized Wurie's flip phone and, after noticing repeated calls from a contact labeled 'my house,' they opened the phone to view its call log and determine the associated number.
- Using this number, police traced Wurie's address, secured a search warrant for his apartment, and discovered drugs, a firearm, and cash.
Procedural Posture:
- In California state court, Riley moved to suppress evidence from his cell phone; the trial court denied the motion, and he was convicted.
- The California Court of Appeal affirmed Riley's conviction, and the California Supreme Court denied his petition for review.
- In federal court, Wurie moved to suppress evidence derived from his cell phone search; the U.S. District Court for the District of Massachusetts denied the motion, and he was convicted.
- The U.S. Court of Appeals for the First Circuit reversed the district court's decision, vacating some of Wurie's convictions.
- The U.S. Supreme Court granted certiorari in both cases to resolve the common legal question.
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Issue:
Does the Fourth Amendment permit police officers to conduct a warrantless search of the digital contents of a cell phone seized from an individual incident to a lawful arrest?
Opinions:
Majority - Chief Justice Roberts
No, the Fourth Amendment does not permit police to conduct a warrantless search of a cell phone's digital contents incident to an arrest. While the search-incident-to-arrest doctrine established in Chimel and Robinson was justified by the need for officer safety and evidence preservation, these rationales do not apply with the same force to digital data. Digital data cannot be used as a weapon, and once the phone is secured, the risk of an arrestee destroying evidence is eliminated; concerns like remote wiping can be mitigated by disabling the phone's network connection. Conversely, the privacy interests at stake are immense, as modern cell phones contain vast quantities of diverse, sensitive personal information, making their search a far greater intrusion than the physical searches contemplated in prior cases. Given this imbalance, the Court holds that officers must obtain a warrant before searching a seized cell phone.
Concurring - Justice Alito
I agree with the judgment that law enforcement must generally obtain a warrant before searching a cell phone, though I reach this conclusion for somewhat different reasons. I disagree with the majority's premise that the search-incident-to-arrest exception is based solely on officer safety and evidence preservation; historically, it was also justified by the need to find evidence of the crime. Despite this broader historical justification, mechanically applying this old rule to the digital era is unworkable because modern phones store an unprecedented quantity of sensitive personal information. The Court's categorical rule requiring a warrant is the most practical solution, though I would be open to reconsidering the question if legislatures enact statutes that draw reasonable distinctions for law enforcement needs while protecting privacy.
Analysis:
Riley v. California is a landmark Fourth Amendment decision that establishes heightened privacy protections for digital information in the modern era. The ruling prevents the search-incident-to-arrest doctrine from becoming a tool for broad, warrantless digital searches, affirming that an individual's data is not a searchable 'container' akin to a wallet or cigarette pack. This decision forces law enforcement to demonstrate probable cause to a magistrate before accessing the vast repository of personal information on a cell phone, setting a crucial precedent for how constitutional principles adapt to new technologies. It signals that courts will focus on the qualitative and quantitative nature of a privacy intrusion rather than relying on outdated physical analogies.
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