Facts – David Leon Riley was stopped by traffic police on 22nd august 2009. He was driving the vehicle with an expired license and expired registration. Police conducted an intensive search of Riley’s vehicle for further findings. Police found two handguns from the vehicle and it was further concluded that Riley was involved in killings of rivals’ gang members. Police also searched his pockets and explored his cell phone in order to get some further clues from his phone. All the text messages, videos, pictures and contacts were explored and police got some crucial evidence that suggested them to place Riley under Police arrest.
History- Riley’s attorney pleaded before the court to suppress each and every evidence that police recovered from Riley’s cell phone while his search and arrest. His attorney argued that these evidences cannot be used against Riley because the search itself was illegal and violated Riley’s fourth amendment rights that are ensured to every US citizen by the US constitution. Riley’s defence arguments were refused by the trial court. The trial court held that search by police was very much legitimate under provisions of SITA doctrine. Riley was convicted and was sent to prison.
Riley went into appeal but his appeal was rejected by the court. The appellate court relied on People Vs Diaz, a previous judgement by the Californian Supreme Court. In the previous judgement, it was held that SITA doctrine does not prevent police from searching individuals and their belongings.
Riley moved into Californian Supreme Court but again he was refused any relief and court reiterated that search by police was absolutely valid and did not violate provisions of SITA doctrine. Riley’s plea of violation of his rights of fourth amendment was also refused by the Court. The court held that US supreme court has decided various cases wherein it was held that searches and seizures of individuals by police are valid and do not violate fourth amendment rights. The Californian court relied upon United States vs. Edwards case wherein it was held that search of suspect was valid even if it was done after 90 minutes of his arrest.
Issue- the major issue, in this case, before the court was to decide whether search of individuals by police was a violation of fourth amendment rights of US constitution. Court had to decide whether searches by police can violate rights of individuals that are provided to them by various constitutional provisions. Secondly, court was to decide whether such searches contradicted provisions of SITA doctrine.
Decision – when the case came before the US supreme court, it was combined with a similar case i.e. United States vs. Wurie on the same legal issue. Wurie had also searched by the police in a similar manner by the police before his arrest. Riley argued that searches by police officers violate his fourth amendment rights, and since cell phones do not cause any threat to life of police officers at the time of search or otherwise, police have no right to search cell phones. It was further argued by his counsel that there is a difference of opinion among various state supreme courts and some of them hold that fourth amendment rights are violated by the search while other courts do not buy this opinion and they find it irrational. It was further argued that if police is given such rights of search and seizure, liberty and life of every American citizen will be at risk.
Chief justice of US Supreme Court John Roberts delivered the verdict in the case. He concluded that without a warrant, police have no right to search cell phones of suspects. Justice John Roberts held, “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. Law enforcement officers remain free to examine the physical aspects of a phone to ensure that it will not be used as a weapon . Once an officer has secured a phone and eliminated any potential physical threats, however, data on the phone can endanger no one” (Kanovitz 617).
Reason- the basic reason that was cited by the majority of decision makers is that police have no right to search cell phones of individuals. Such search violates the fourth amendment rights of people that are given to them by US constitution. The bench also believed that cell phones do not cause any threat to police officers and thus there is no need to search them. Individuals have a number of text messages, pictures, videos and other information of their friends and families and searching such information by police certainly violates privacy rights of US citizens.
Concurring opinion- justice Samuel Alito filed a concurring opinion in this case. He partly agreed with the judgment and partly dissented with it. He said that legislative should take a clear decision on the issue. He also suspected that this decision will increase unnecessary technicality for police. He said that cell phones have become very sophisticated device in modern times and their role in covering up or hiding evidences cannot be underestimated.
Work Cited
Kanovitz, Jacqueline R. Constitutional Law for Criminal Justice. New York, NY: Routledge, 2015.
