U.S. v. Wood

In prosecution on receipt and possession of child pornography charges arising out of search of defendant’s cellphone, under circumstances, where defendant was initially arrested on violation of his parole, and where search of cellphone to recover stored data occurred seven days after officer discovered methamphetamine in defendant’s cellphone during defendant’s arrest on parole violation. Dist. Ct. could properly find that holding in Riley, 573 US 373, which generally precludes warrantless searches of cellphones incident to lawful arrest, did not apply to parolees. Moreover, warrantless, suspicionless search of parolee is reasonable under 4th Amendment given parolee’s reduced privacy expectations (where parolee can be searched based on less than probable cause) versus state’s greater interests in reducing recidivism and promoting reintegration. Ct. rejected defendant’s claim that cellphones were not covered by operative probation agreement.