Syllabus
First Circuit reversed the denial of the motion to suppress and vacated the relevant convictions.
Held: The police generally may not, without a warrant, search digital information on a cell phone seized from an individual who has been arrested. Pp. 5-28.
(a) A warrantless search is reasonable only if it falls within a specific exception to the Fourth Amendment's warrant requirement. See Kentucky v. King, 563 U. S. ____, ____. The well-established exception at issue here applies when a warrantless search is conducted incident to a lawful arrest.
Three related precedents govern the extent to which officers may search property found on or near an arrestee. Chimel v. California, 395 U. S. 752, requires that a search incident to arrest be limited to the area within the arrestee's immediate control, where it is justified by the interests in officer safety and in preventing evidence destruction. In United States v. Robinson, 414 U. S. 218, the Court applied the Chimel analysis to a search of a cigarette pack found on the arrestee's person. It held that the risks identified in Chimel are present in all custodial arrests, 414 U. S., at 235, even when there is no specific concern about the loss of evidence or the threat to officers in a particular case, id., at 236. The trilogy concludes with Arizona v. Gant, 556 U. S. 332, which permits searches of a car where the arrestee is unsecured and within reaching distance of the passenger compartment, or where it is reasonable to believe that evidence of the crime of arrest might be found in the vehicle, id., at 343. Pp. 5-8.
(b) The Court declines to extend Robinson's categorical rule to searches of data stored on cell phones. Absent more precise guidance from the founding era, the Court generally determines whether to exempt a given type of search from the warrant requirement "by assessing, on the one hand, the degree to which it intrudes upon an individual's privacy and, on the other, the degree to which it is needed for the promotion of legitimate governmental interests." Wyoming v. Houghton, 526 U. S. 295, 300. That balance of interests supported the search incident to arrest exception in Robinson. But a search of digital information on a cell phone does not further the government interests identified in Chimel, and implicates substantially greater individual privacy interests than a brief physical search. Pp. 8-22.
(1) The digital data stored on cell phones does not present either Chimel risk. Pp. 10-15.
(i) Digital data stored on a cell phone cannot itself be used as a weapon to harm an arresting officer or to effectuate the arrestee's escape. Officers may examine the phone's physical aspects to ensure that it will not be used as a weapon, but the data on the phone can endanger no one. To the extent that a search of cell phone data
