Riley v. California

Supreme Court of the United States · 2014 · Criminal Procedure

134 S. Ct. 2473 (2014)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentSearch incident to arrestCell phone searchesWarrant requirementcell phonedigital dataexigent circumstances

Facts

Riley was stopped for expired registration tags, arrested after an inventory search of his car revealed firearms, and officers then seized and later examined his smart phone without a warrant, finding gang-related videos and photographs used against him at trial. Wurie was arrested after an apparent drug sale, and officers at the station seized his flip phone, opened it after seeing repeated calls from "my house," accessed the call log and number information, and used that information to locate an apartment later searched under warrant. In both cases, the defendants sought suppression on the ground that the initial warrantless search of the phone data violated the Fourth Amendment. The cases presented the same question about warrantless searches of digital information on cell phones seized from arrestees.

Issue

May police, without a warrant, search digital information on a cell phone seized from an individual who has been lawfully arrested? More specifically, does the search-incident-to-arrest exception permit officers to examine the phone's digital contents just because the phone was found on the arrestee's person?

Rule

The search-incident-to-arrest exception does not generally permit police to search digital information on a cell phone seized from an arrestee. Officers may examine the phone's physical aspects to ensure it is not a weapon and may seize and secure the phone to prevent destruction of evidence, but they generally must obtain a warrant before searching the phone's data, absent a case-specific exception such as exigent circumstances.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, officers lawfully arrest Nolan Price on a burglary warrant and remove a smart phone from his jacket pocket. After handcuffing Nolan and placing the phone in an evidence bag, a detective scrolls through his text messages at the station without first seeking a warrant, hoping to find the names of possible fencing partners.

Is the detective's warrantless review of the text messages most likely constitutional?

Explanation. The majority held that police generally must obtain a warrant before searching digital information on a cell phone seized incident to a lawful arrest. Officers may seize and secure the device, but the categorical search-incident-to-arrest rule for physical objects does not extend to digital data. Once the phone is secured, the officer-safety and evidence-preservation rationales do not justify a routine warrantless search of its contents.