U.S. v. Jenkins

In prosecution on charges of drug conspiracy and distribution, Dist. Ct. erred in denying defendant’s motion to suppress warrantless search of his cell phone found at scene of his arrest, even though search was limited to identifying defendant’s cell phone number. Under Riley, 134 S.Ct. 2473, warrant must be obtained prior to searching arrestee’s cell phone data. Moreover, while Riley was decided after instant search, no prior 7^th Circuit precedent cited by govt. to support instant search specifically authorized warrantless search of arrestee cell phone. Any error, though, was harmless since linkage of defendant’s cell phone number to drugs at issue in charged offense was established through other properly admitted evidence.