Following is the case brief for Riley v. California, Supreme Court of the United States, (2014)
Case Summary of Riley v. California:
- Riley was convicted of a shooting related offense after evidence seized from his cell phone (incident to his arrest) was used against him in court.
- Riley filed a motion to suppress which was denied and later appealed to the state’s court of appeals claiming the search violated his Fourth Amendment rights.
- Riley, along with and similarly situated Wurie, petitioned the Supreme Court in a consolidated case.
- The Supreme Court held that the government may not conduct a warrantless search of a cell phone’s contents that was seized after an arrest absent any exigent circumstances.
Riley v. California Case Brief
Statement of the Facts:
Officers pulled over Riley for a traffic violation, which led to his arrest on weapon-related charges. Riley was searched after his arrest and officers seized his cell phone from his pocket. Riley was convicted after a trial where evidence seized from his phone was introduced in a shooting related charge. In response, Riley appealed his conviction to the California state court of appeals. The court upheld the trial court’s conviction.
Another defendant, Wurie, had his flip phone seized incident to arrest. Officers used the items seized in the phone to secure a search warrant to search Wurie’s home. After the district court admitted the evidence found at the residence, Wurie appealed. The federal court of appeals found that the evidence was the fruit of an illegal search of the phone.
The cases were consolidated and the Supreme Court of the United States granted certiorari.
The district court permitted the evidence to be introduced. On appeal the federal court of appeals reversed holding the evidence was the fruit of an illegal search of the arrestee’s phone. The Supreme Court granted certiorari.
Issue and Holding:
May the government conduct a warrantless search of the contents of a cell phone seized after an arrest when no exigent circumstances exist? No.
Rule of Law or Legal Principle Applied:
The government may not conduct a warrantless search of the contents of a cell phone that is seized incident to an arrest absent exigent circumstances, under the Fourth Amendment.
The judgment of the federal court of appeals is affirmed and the judgment of the state court of appeals is reversed.
- Generally, officers must obtain a warrant before conducting a search of the contents of a cell phone seized incident to an arrest. Otherwise, a Fourth Amendment violation occurs.
The exception to search a person incident to an arrest is a valid exception to the warrant requirement of the Fourth Amendment. The exception is permitted for officer safety and to prevent destruction of evidence. However, no safety risk exists in a cell phone that warrants intrusion beyond a preliminary search to make sure the phone is not holding a weapon or small blade. The Court then distinguishes the warrantless search of a cell phone from other objects such as a cigarette container.
The Court then considers the separate indigent circumstances exception and whether it applies. The Court held that once officers have secured a cell phone, there is little risk of destruction of stored evidence. The concerns of protecting against remote wiping is beyond the concerns expressed in Chimel v. California, 395 U.S. 752 (1969), which is that an arrestee may destroy evidence that is within reach.
Although an individual’s privacy rights are diminished once arrested, it should not be treated as a complete deprivation. The Court then distinguishes the search of a cigarette pack from the privacy invasion at issue regarding a search of a cell phone or residence and determines such a search is not constitutional. The search of the data on a cell phone is a major invasion of privacy due to the quality and quantity of information stored on phones.
The Court also concludes the government’s assertion that under Arizona v. Gant, 556 U.S. 332 (2009), a warrantless search of a cell phone is justified when the cell phone is reasonably believed to contain evidence of the crime of arrest, applies to the search of vehicles and is inapplicable to a cell phone. Absent a warrant or demonstration of exigent circumstances, the government may not conduct a search of a cell phone incident to arrest.
Concurring and Dissenting opinion:
The history of the search-incident-to-arrest exception is substantially based more on probative evidence than the destruction of evidence and officer safety. Regardless, the majority correctly holds the rules of a physical search do not apply to cell phone data.
Riley v. California established that a search of information found in a cell phone is not a proper search incident to an arrest. Due to the personal nature of information stored in a cell phone, a search warrant must first be obtained.