Summary
The conviction of Riley hinged upon evidence seized by the police from his cell phone which was presented in a court of law. The search violated the Fourth Amendment Rights which led Riley to file a motion of suppression that was denied and later on led to an appeal in the state’s court of appeal. Along with Wurie, Riley petitioned the Supreme Court, basing his arguments in a consolidated case. According to the ruling by the Supreme Court, the government violates an individual’s rights in the case where it performs a seized cell phone content search done after an arrest in the absence of exigent circumstances. Based on the evidence, the Fourth Amendment rights, the petition and the lack of exigent circumstances, the Supreme court altered the previous ruling.
Facts
The expired registration tags gave the police officer probable cause to stop Riley. Upon stopping, it came to the police officer’s knowledge that Riley did not have a valid license as it was under suspension. As per the rule of law, Riley’s car was impounded. After an inventory search by another officer, it led to the discovery of two handguns that were under the hood of the car. As a result, the police placed Riley under arrest, with the charges being possession of firearms that were concealed and loaded. Another search incidence is resulting in the police officers retrieving a cell phone from Riley’s pant pockets. The police examined the phone which led to the discovery of photos linking Riley to other crimes. Some of the images present in the cell phone found were admissible into evidence at trial, and the investigating officer went ahead to testify using some of Riley’s cell phone contents.
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Brima Wurie made a drug sale that was apparent as observed by a police officer. The incident led to the arrest of Wurrie by the officer. The police officers seized two cell phones on Wurie upon getting to the police station, one of the cell phones was a flip phone. One caller labeled “My House” constantly contacted Wurie. Upon accessing the phone, the police saw the wallpaper being a woman and baby’s picture. After accessing the call log, the police officers determine “My House” phone number, which led to tracing the number to an apartment building. The officers went into the building where they saw on the mailbox Wurie’s name. The building was secured before obtaining a search warrant that led to the discovery of drugs, firearm, cash, and ammunition.
Procedural History
By appealing to the US Supreme Court, after a denied petition in the Californian Supreme Court, Riley followed the proper procedural channels with the aim of having the court review his case and pass a ruling that recognized the validity of the fourth amendment. The petition aimed to have the US Supreme Court affirmed the decision by both the California trial and Supreme Court concerning Riley’s conviction of having fired on a vehicle that had occupants using a seeming automatic firearm. Although the charges against Riley were attempted murder, Riley’s appeal aimed to reject the court holding evidence found on his phone as the procedure of getting it was not legal. While the lower court coupled with the California Supreme court advocated for a warrantless search of the suspect’s cell phone as long as the relationship between the suspect and the phone is apparent.
By combining Riley’s case with that of United States v. Brima Wurie (First Circuit), the appeal to the United States Supreme Court that intended to reverse the ruling on Wurie’s case where the police used the suspect’s phone to find and confiscate evidence that was later used in a court of law to convict him. As per the ruling of the lower courts, the warrantless phone searches were illegal as per the Fourth Amendment statutes. Furthermore, the lower court ruling asserted that phones were different from other physical possessions due to their ability to hold numerous information, some of which may be private and confined to a single party. The technological advancement promotes innovativeness and privacy as a priority; hence the most information available on the cell phones should remain in private unless a warrant is available. As per the conditions of the Fourth Amendment, the government needs probable cause to present a search warrant hence unless law enforcement officers have in place reliable evidence, they should not search one’s phone contents.
Summary of Court’s Decision
The case plays a necessary role in the Fourth Amendment concerning privacy issues and the effect on millions of Americans. Majority of arrests made yearly across the nation are a result of an alleged misdemeanor with most individuals never getting convicted. Riley v. California highlights a ruling by the lower court that not only can a police officer confiscate a cell phone belonging to a suspect, they can also search the phone’s content for any signs of criminal activity even in the absence of a search warrant.
The case’s petitioner and defendant, David Leon Riley were placed under arrest the twenty-second of August, 2009 after being stopped by a police officer who found concealed guns in the suspect’s vehicle. Subsequently, the officer seized the suspect’s phone, went through the phone’s content, including videos, messages, and contacts. Using the phone’s data, the officer presented a charge against Riley connecting him to another crime that was unrelated to the arrest.
The move by Riley aimed to suppress the presented evidence because the officer failed to provide a search warrant before going through his cell phone and identifying the incriminating evidence. According to Riley, the act violated his Fourth Amendment rights; however, the trial court rejected Riley's claim and held that the search was within the confines of the law, hence the conviction of Riley. The ruling of the court came under affirmation in the judgment of the California Supreme Court decision concerning the People v. Diaz. In the Diaz case, the holding by the court was that the “Search-Incident-to-Arrest “doctrine in the Fourth Amendment, police officers are not restricted by the law from performing a full exploratory analysis of the phone contents whenever and wherever the phone is found as long as it has ties to the culprit.
Currently, a split exists concerning the phone search-incident-to-arrest doctrine. According to a ruling by the Fourth, Fifth and Seventh Circuits, officers have the go-ahead to search phones in cases where they conduct an arrest in the presence of various standards. As such, the ruling from Riley v. California is still evolving.
The Implication for The Future
The legal consequences in Riley’s case are uncertain, however, as per the ruling of the court, one’s interest in their phone presents a scenario that requires special protection. The future is thus uncertain. Although Chief Justice Robert presented a ruling that aligns itself to the regulations and requirements of the Fourth Amendment precedent, the prediction by Justice Alito asserts the presence of inconsistent results. The irony thus arises in where information that has a different media source, for example, physical photos, notes, and receipts do not come under protection during arrest situations, however, the same information is privy to security if the storage is in an electronic medium hence without a warrant, looking at the information violates the Fourteenth Amendment. Furthermore, a permit is subject to probable cause which means, without the officers having a good reason for the search, the information on the phone remains protected.
Such a situation promotes a biased policy where those storing information on electronic mediums have privacy rights while those that carry physical information are not subject to the same condition. The protection of the same information is a guarantee unless the officer has probable cause for concern to question the suspect, in which, they must seek a warrant before carrying out any searchers on the phone. With the advent of cloud computing, storage of such information guarantees legal protection against incursion on one’s privacy without a warrant. The law enforcement, thus, has to deal with the dilemma of not accessing one's cloud computing system as they cannot use the suspect's phone without a warrant which also limits the future access to the same information. Furthermore, the decision by culprits to get rid of other sources of information and instead rely on electronic information storage will weigh heavily on the ability of the police officers to get intel. Riley's case presents a majority view of the phone being a portable container, hence the warrant has to rely on probable cause before its issuance.
Biblical Worldview
The biblical view of the Riley case could be diverse. According to the third, regardless of whether a nation is at war or peace, no soldier can enter into a house without the consent of the owner. On the other hand, the fourth amendment the home and castle analogies present a stern warning against entry into another’s house without probable cause. Furthermore, such warrant is only applicable and issued on the grounds of probable cause without a doubt with the warrant specifying where to search. The Home and Castle is dependent on the definition in Deuteronomy 24:10-11 which asserts,
“ When thou dost lend thy brother anything, thou shalt not go into his house to fetch his pledge. Thou shalt stand abroad [remain outside, NASB], and the man to whom thou dost lend shall bring out the pledge abroad unto thee.”
Considering the court ruling asserts the cell phone to be a moving container, the biblical view calls for the police officers to uphold privacy in the same matter. However, the Mosaic view is not absolute; hence it gives the police officers a loophole if, they recognize the presence of a crime without a doubt. As such, one could quote the Mosaic biblical view if they have strong probable cause in the absence of a search warrant.
Personal Opinion
The rationale behind the ruling compelled with the example, precedence from other cases, I find the verdict quite opaque. While the justification for the decision is to ensure people’s, privacy is not under any violation; the police have to gain insight and useful information on behalf of the state. Kentucky v. King presents the belief that, the reasonability of a search warrant is dependent upon the requirements put forth in the Fourth Amendment. However, in Riley’s case, the incident presents a situation where invalidation of a search warrant is possible in the event of a warrantless search and an unlawful arrest. The ruling fails to illustrate whether the police have a right due to the quest not only to see, but also confiscate the suspect’s phone, or whether, they should view the phone’s data. The attempt to explain the scenario is present in the United States v. Robinson where a police officer got away with looking in a cigarette pack, an extension that was not applicable in Wyoming v. Houghton. While each party is justified in their arguments, the law enforcement officers should be allowed to present evidence retrieved from phones into court trials.
However, I agree with the court’s ruling that, mechanical application of the rule should not be applied especially in an era where everything hinges on the digital framework. Currently, cell phones contain numerous information, some that are very personal hence should not be accessible to third parties. On the other hand, the biased nature of the ruling leaves one to contemplate on the possible ways of reforming the legal system. The irony comes to question when the same information differs in judgment levels where only electronic media remains under the protection of the fourteenth amendment while other mediums including snapshots and notes are admissible in court as evidence.
References
Rainer, R. K., & Cegielski, C. G. (2011). Introduction to information systems . Hoboken, N.J: John Wiley & Sons.
Sprigman, C. J. (2017). The Indigo book . Sebastopol, CA: Public. Resource. Org
Walker, J. T., & del Carmen, R. V. (2014). Briefs of leading cases in law enforcement . Routledge.
