Held: The police generally may not, without a warrant, search digital information on a cell phone seized from an individual who has been arrested.

I believe that the holding in Riley v. California is narrow because of the specificity of the sentence.  After the case of Robinson the Court declined to extend its categorical rule, allowing the search of destructible evidence, to searches of data stored on cell phones.  With this decision, I believe that we are able to understand that any data or messages on a cell phone can be argued to be “digital information.” While the term “digital information” may be general as it should be argued data on a cell phone is much the same information as someone would have on a laptop or tablet, the holding strictly refers to the inappropriate seizing of the arrested individual’s cell phone, not laptop or tablet.  That being said the first part of the holding, that reads “the police generally may not,” is used in order to show that there are exceptions to this holding, which would create a more general decision.

Based both on the rationale behind the holding and the examples of precedence that are given, I believe that the holding is pretty opaque.  The rationale for the holding is to enforce people’s fourth amendment rights in respecting their privacy but also to gain useful information for the state; as stated in paragraph (b) of the Riley syllabus. The examples of horizontal precedence, or stare decisis, are Chimel v. California, United States v. Robinson, Arizona v. Gant, and Wyoming v. Houghton. As there is so much information and arguments on both sides of the previous cases and the rationale, I believe that the holding is still yet to be developed fully as a clear rule to either entirely protect and assist law enforcement or entirely protect the citizen’s fourth amendment rights.

Paragraph (a) states that “A warrantless search is reasonable only if it falls within a specific exception to the Fourth Amendment’s warrant requirement. See Kentucky v. King…” In Riley’s case, we look at the exception to warrant necessary to search when a warrantless search is conducted incident, or as a result of, a lawful arrest.  What the holding does not completely cover is whether this search gives the police the right to simply see and confiscate the phone or the right to look through the data stored within the phone.  This difference is attempted to be explained in United States v. Robinson when it is brought up that a police officer was allowed to look inside a cigarette pack, but this extension was, like I wrote before, later declined in Wyoming v. Houghton.  I can see a future case of warrantless search being argued by the defense as fitting one of the specific exceptions to the Fourth Amendment’s requirement but the prosecution demanding that the holding of Riley and many other Supreme Court cases should be proof enough that digital information may not be used as evidence unless a warrant is granted.