U.S. v. Berrios

In prosecution on Hobbs Act robberies, Dist. Ct. did not commit reversible error in denying defendant's motion to suppress evidence obtained through warrantless search of his cellphone. Under Riley, 573 U.S. 373 (2014), police normally need warrant to search contents of cellphone that had been seized incident to arrest, and Riley retroactively applies to instant case. Moreover, while there was no binding authority at time of instant search that would have permitted instant warrantless search, items of evidence government found in cellphone had independent source, and thus were admissible at trial on that ground.