Riley v. Cal. United States
134 S. Ct. 2473
| SCOTUS | 2014Background
- Riley stopped for traffic violation; arrested on weapons charges; police seized his cell phone incident to arrest.
- An officer accessed phone data; later a gang-dangering investigation used photos/videos from the phone.
- California state proceedings denied suppression; Riley convicted and sentenced.
- Wurie arrested after observed drug sale; seized a cell phone; officers opened call log using external label; traced to apartment with drugs and firearm.
- First Circuit reversed denial of suppression; government sought certiorari; issues framed around warrantless cell phone data searches.
- The Supreme Court held that, generally, a warrant is required to search digital data on a cell phone seized incident to arrest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a search incident to arrest extends to digital data on cell phones | Riley/Wurie argue Robinson applies | Government/California propose exceptions or analogies to Gant | Warrant required; generally cannot search phone data without a warrant |
| Whether Chimel/Robinson justification justifies a warrantless cell-phone data search | Data could be searched under Robinson's logic for immediacy | Robinson justification applies to physical items, not digital data | No; extend Robinson to digital data is improper; warrant required |
| Whether exigent circumstances could justify a warrantless cell-phone search | Exigent circumstances could permit immediate search | Exigency could justify in limited cases | Exigent circumstances may justify in particular cases, but not as a general rule for cell phones |
| How privacy interests of digital data compare to physical items | Digital data is broader and more private | Analogies to physical items are acceptable | Court weighs privacy interests; generally warrants required for digital data |
| Whether data stored remotely (cloud) or protected by encryption affects search rule | Cloud storage/encryption raise unique concerns | Search framework should cover these technologies | Warrant requirement remains; remote wiping/encryption do not justify blanket destruction of privacy protections |
Key Cases Cited
- Chimel v. California, 395 U.S. 752 (1969) (established search-incident-to-arrest limits based on officer safety and evidence preservation)
- United States v. Robinson, 414 U.S. 218 (1973) (expanded Chimel to searches of arrestee’s person)
- Arizona v. Gant, 556 U.S. 332 (2009) (vehicle searches; context for Chimel/vehicle exception)
- United States v. Chadwick, 433 U.S. 1 (1977) (limits on searches of containers; immediate association with arrestee)
- Wyoming v. Houghton, 526 U.S. 295 (1999) (balancing test for reasonableness of searches)
- Kentucky v. King, 563 U.S. _ (2011) (exigent circumstances as exception to warrant requirement)