This Supreme Court case from 2014 brought the Fourth Amendment into the digital age. David Leon Riley belonged to a gang in San Diego, California. In August of 2009, Riley and other gang members opened fire on a rival gang member while driving past him. Everyone fled in Riley’s car. A few weeks later, Riley was pulled over for an expired license registration tag in a different vehicle. Riley’s license turned out to be suspended and his car was going to have to be impounded. According to police policy, a car must be searched for all of its inventory to protect against the police department from liability claims in the future. During the search, the police located two guns and arrested Riley for possession of firearms. The police also confiscated Riley’s phone and a detective analyzed his pictures and videos. He found that Riley was a gang member and was tied to the shooting earlier that month. Riley was charged with shooting at an occupied vehicle, attempted murder, and assault with a semi-automatic firearm. As the case progressed through different courts, the issue became whether or not the information/evidence gathered through Riley’s phone was admissible. The California Courts said it was okay to admit evidence from Riley’s phone. The Supreme Court differed and their decision made this case one of America’s landmark cases.
The ruling now requires that authorities obtain a warrant before searching a seized cell phone after an arrest. A warrantless cell phone search violates the Fourth Amendment right to privacy. Although this ruling may not seem like anything extraordinary to the average person, it hints at the fact that the Court is ready to engage with challenges it will face in the digital age ahead. This ruling also signals that the Court is concerned with the privacy of its citizens in this age of technology. We may see the court taking a pro-privacy approach in the future as well.
The Court identified many reasons for affording cell phones greater Fourth Amendment protections than physical records. Chief Justice Roberts explained these reasons:
- Cell phones have an immense storage capacity and can store millions of texts, pictures, and videos.
- Cell phones are able to aggregate many distinct types of information in one place.
- Data on cell phones usually includes “private information never found a home in any form.”
- Cell phones can serve as a portal to private records stored on remote servers. One click on a phone can give someone access to data stored elsewhere. This refers to cloud computing.
Not only did the Justices focus on the quantity of data stored in cell phones, they also looked at the quality of personal information. The Fourth Amendment was put in place by the Founding Father’s in order to maintain the privacy of the colonists. When British officers started rummaging through the home of people looking for criminal activity, the Founding Fathers knew there was a problem. This Supreme Court decision shows the privacy of Americans still needs to be protected. Many of the statements Chief Justice Roberts made along with the unanimous court showed that the NSA’s bulk record collection program may not be the best route for increased national security either.
Chief Roberts concluded the unanimous court decision by saying something that will definitively go down in the history books, “The fact that technology now allows an individual to carry such information in his hand does not make the information any less worthy of the protection for which the Founders fought.” We hope this in-depth analysis of Riley has helped our readers better understand their rights.