Demby v. State, 118 A.3d 890

On May 24, 2012, Maryland State Police responded to a report of suspected drug activity at a park; officers found Demby in a car with another man and identified drugs and prescription pills.
Corporal Leonard Nichols arrested Demby, noticed a ringing cell phone on the dashboard, asked who owned it, and Demby said it was his.
Nichols "opened" the (non-smart) phone at the scene and read the most recent text messages, which he believed indicated drug sales; he then seized the phone and later obtained a warrant to search its contents.
The circuit court denied Demby’s motion to suppress the phone data, ruling the on-scene viewing was a permissible search incident to arrest (and alternatively relying on inevitable discovery).
Demby was convicted after an agreed statement of facts; the Maryland Court of Appeals granted certiorari to consider whether Riley v. California requires suppression and whether inevitable-discovery or good-faith exceptions apply.
The Court held that although Riley establishes that warrantless cell-phone data searches incident to arrest are generally unconstitutional, the officer here reasonably relied on pre-Riley precedent (United States v. Robinson), so the good-faith exception (Davis) bars suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reading text messages on Demby’s phone at the arrest violated the Fourth Amendment	Demby: Riley requires a warrant to search cell-phone data; on-scene reading violated Fourth Amendment	State: phone was a non-smart phone; officer only viewed recent messages and acted under plain-view-like facts	Court: The search violated Riley’s rule but officer acted in objectively reasonable reliance on Robinson before Riley, so suppressions not required under good-faith doctrine (Davis)
Whether evidence is nevertheless admissible via inevitable discovery or other exceptions	Demby: Exclusion required because search was warrantless and unconstitutional under Riley	State: Evidence admissible either because it would have been inevitably discovered or because officer acted in good faith reliance on existing precedent	Court: Did not need to decide inevitable discovery; applied good-faith exception and affirmed admission of the phone data

United States v. Robinson, 414 U.S. 218 (search incident to lawful arrest permits search of items found on arrestee)
Riley v. California, 573 U.S. 373 (2014) (warrantless searches of cell-phone digital data incident to arrest generally unconstitutional)
Davis v. United States, 564 U.S. 229 (2011) (good-faith exception where officers reasonably rely on binding precedent)
Nix v. Williams, 467 U.S. 431 (1984) (inevitable discovery doctrine)
Horton v. California, 496 U.S. 128 (1990) (plain-view doctrine)