Riley v. California
The U.S Supreme Court
Decided on June 25, 2014
Digital Data Stored On A Cell Phone Does Not Fall Into One Of The Exceptions To The Warrant Requirement
Summary: Defendant Riley was pulled over by police for a traffic violation. Police searched Defendant and seized his cell phone. The police accessed information on his phone through photographs, videos, and text messages. They discovered a term “CK” associated with a street gang that led to Defendant’s arrest on a weapons charge. The State subsequently charged Defendant with a shooting that occurred a few weeks earlier and sought to enhance his sentence based on information of his gang’s membership. At trial, Defendant moved to suppress all evidence that the police obtained from his cell phone; the trial court denied that motion and convicted defendant in connection with an earlier shooting, assault with a semiautomatic firearm, and attempted murder. The. U.S Supreme Court granted certiorari.
Defendant Wurie was observed by police making an apparent drug sale and was arrested. At the station, police seized Defendants phone and noticed multiple incoming calls from a contact “my house”. The police flipped open Defendants phone and searched his contacts. Police associated the incoming call labeled “my house” to Defendants apartment. Police obtained a search warrant and found drugs, firearms, cash and ammunition. Defendant moved to suppress the evidence from the search of his apartment. The trial court denied that motion and Defendant was convicted of possessing crack cocaine with intent to distribute, and, being a felon in possession of a firearm. The U.S Supreme court granted certiorari.
See Also: The Police Aint Dracula: They Cant Take Your Blood Without A Warrant
Issue: Whether police can search the contents of digital information on a cell phone seized from an individual as an incident to an arrest without a warrant.
Holding: No. The United States Supreme Court held that police generally may not, without a warrant, search digital information on a cell phone seized from an individual who has been arrested. Digital data stored on a cell phone does not fall into one of the expectations to the warrant requirement and cannot itself be used as a weapon to harm an officer, nor can it be searched to which it is needed for the promotion of legitimate governmental interest without first obtaining a warrant. Such a concern is addressed through consideration of case-by-case exception to the warrant requirement in exigent circumstances.
Facts: David Riley was stopped by police for driving with an expired registration. Police seized the car, searched it, and found Defendant in possession of loaded firearms. At the station, police seized Riley’s phone and accessed information. Police went through text messages and contacts list and found the letters “CK”, a label that stood for “Crip Killers”, a slang term for members of the Bloods gang. A detective who specialized in gangs furthered the search of Defendants phone by looking through pictures and videos. They found photographs of Riley standing in front of the car they suspected had been involved in a shooting a few weeks earlier. Riley was charged, in connection with the earlier shooting, with firing at an occupied vehicle, assault with a firearm, and attempted murder. Riley’s sentence was enhanced by the State.
The State alleged that Riley committed those crimes for the benefit of a criminal street gang, an aggravating factory that carries an enhanced sentence. Prior to trial, Riley moved to suppress all evidence that the police obtained from his cell phone stating that the searches of his phone violated the Fourth Amendment because the police did not have a warrant and were not justified by an exigent circumstance. The trial court denied that motion. The California Court Of Appeals affirmed and held that the Fourth Amendment permits a warrantless search of cellphone data incident to an arrest, so long as the cell phone was immediately associated with the Defendant’s person. The U.S Supreme Court granted certiorari
Police suspected Defendant Brima Wurie made an apparent drug sale from a car and arrested him. At the station, the police seized two cell phones from his person. Defendant Wurie’s phone was repeatedly receiving incoming calls from a source identified as “my house”. Police further investigated the source by going through Defendant’s contacts and used an online phone directory to trace that contact to an apartment building. The officers went to that apartment and noticed that Wurie’s name was printed on the mailbox. The police obtained a search warrant and searched Defendant’s apartment seizing 215 grams of crack cocaine, marijuana, drug paraphernalia, a firearm and ammunition, and cash. Defendant was ultimately charged with distributing crack cocaine, possessing crack cocaine with intent to distribute, and being a felon in possession of a firearm with ammunition.
Prior to trial, Defendant moved to suppress the evidence obtained in the search of his apartment, arguing that it was the “fruit of a poisonous tree” of an unconstitutional search of his cell phone. The trial court denied his motion and convicted him on all three counts. A divided panel of the First Circuit reversed the denial of Wurie’s motion to suppress and vacated Worries convictions for possession with intent to distribute and possession of a firearm as a felon. The court held that cellphones are distinct from other physical possessions that may be searched incident to an arrest without a warrant, because of the amount of personal data cell phones contain .The U.S Supreme Court granted certiorari.
Legal Analysis: The U.S Supreme Court held that the warrant requirement is an important component under the Fourth Amendment jurisprudence. Cell phones, which are now a universal and demanding part of daily life, contain vast amounts of personal information. Police can search the physical aspect of a phone to ensure that it will not be used as a weapon; to determine whether there is a razor blade hidden. However, once the police eliminated any potential physical threats, digital data information on the phone can endanger no one and requires a warrant.
The U. S Supreme Court’s Chief Justice held, once police had arrested an individual, they could search items the arrestee had on their person and within the arrestees reach. A ‘search incident to arrest’ exception to the Fourth Amendment warrant requirement had been a feature of criminal law since 1914. The Court did not cast aside any of its prior rulings allowing police to make such searches; it simply declared that they do not apply to cell phones.
An Officer’s search of digital contents on such device, as the Chief Justice said, have the potential to ransack a person’s private life even more extensively that if police, without a warrant, searched an individuals house in every corner from top to bottom. Digital data within the contents of your cell phone have more personal information than a house may have.
It is held that the information on a cell phone is not immune from search; it is instead held that a warrant is generally required before such a search, even when a cellphone is seized incident to arrest.