Jiayao Huang

1/29/2018

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Case Brief: Riley v.
California Supreme Court

Facts

Law
enforcement officers instructed David Riley to halt his
car at the side road for driving the Lexus with expired tags. They impounded
the vehicle after discovering that the offender was using an expired license.
The San Diego police department found two firearms in the confiscated car.
Accordingly, it arrested the offender for the concealed guns and examined his
smartphone. The agency searched Riley’s text messages on the seized phone and
discovered that the lawbreaker might have participated in gang-related offenses.
Later, an investigator found a photograph on the cell phone that linked the law
offender to a motor vehicle used in another gang shooting. In fact, the phone
records proved that Riley was at the crime scene. It is worth mentioning that
the San Diego detectives did not have a warrant for these investigations.
Nonetheless, Riley was charged with shooting due to this evidence. However, he
requested the trial court to put the provided body of facts out of judicial
consideration since the law enforcement officers obtained it through an illegal
search without getting a writ from a judge. Nevertheless, the court refused to
grant the petition, and the California Court of Appeal argued that the
examination was legally acceptable. Consequently, Riley, who presented an issue
related to the Fourth Amendment before the U.S. Supreme Court, wanted judges to
prevent the utilization of information drawn from a phone seized during a
warrantless search; fortunately, the judges made a correct determination by
rendering a decision that favored Riley, which upheld the requirement of the
Fourth Amendment.

History

Riley
requested the court to restrain the use of the evidence obtained during the
search by asserting that its inclusion during the trial amounted to a violation
of the Fourth Amendment rights. However, the trial court concluded that the
argument was invalid and emphasized that it was legal to conduct the
examination during the arrest. The ruling led to the conviction of Riley.
Similarly, the appeals court affirmed the lower court’s decree by relying on an
earlier judgment made in People v. Diaz.
In Diaz, the California Supreme Court
maintained that the Constitution specifies that the police can comprehensively
search a mobile phone found near the person being sued or accused.

The Issue

Riley
presented a Fourth Amendment issue before the highest federal court in the U.S.
The petitioner wanted the judges to determine whether it was legitimate for the
law enforcement agency to examine the contacts, photos, and videos on a mobile
phone that the police take temporary possession of once they take a person into
custody, even if they do not have a warrant. It is important to understand that
the Fourth Amendment allows officers to carry out only reasonable searches.
Hence, the law requires the police to obtain a legal document before checking
the accused individuals or their properties. However, it is not compulsory for
a detective to get a writ from a court when performing such examinations in the
course of a lawful arrest. During warrantless searches, it is the
responsibility of the judiciary to assess whether it is “reasonable” by giving
careful consideration to the protection of citizens’ right to privacy and the
need to uphold the state’s legal interests. Similarly, this lawsuit assessed
the constitutionality of examining an arrested person’s phone based on the
stipulations of the Fourth Amendment.

Decision and Reasoning

The
Supreme Court ruled that officers should obtain a warrant before subjecting a
person and a cell phone to a search when conducting an arrest. It considered
the value of mobile phones and the available data carefully and methodically
while making this determination. In particular, the court maintained that
carrying a warrantless search of the digital information on the phone of a
detained person contravened the U.S. Constitution. It concluded that the
warrant exception that was stipulated in the law to ensure the safety of the
police did not apply to the case since the offender could not use the data either
as a weapon or the means of escape. Besides, the justices rejected the
government’s arguments that the arrestee would have destroyed the evidence.
They maintained that California should have considered more appropriate methods
of preventing data loss instead of checking the accused’s phone without a
warrant. Indeed, the judges argued that it was a rare event for a person to
wipe such information remotely. They pointed out that the U.S. citizens have
privacy interests in these electronic devices because they contain a lot of private
information. Hence, the court concluded that the country’s regulations allow
the law enforcement agency to seize a mobile during an arrest but prohibits
them from examining the digital contents contained in the gadget without a
writ.

Dissenting Opinion and Personal Opinion

The
judges ruled for the petitioner unanimously. I support this judgment because it
adheres to the stipulations of the U.S. Constitutions and the relevant laws.
Indeed, the law allows the police to search digital data without the required
court approval only when there is an evident ongoing emergency. More
importantly, the decision expands the freedom of expression by considering the
significance of mobile phones and the digital information saved in these
gadgets in people’s lives. I understand that the justices did not expressly
focus on the subject of expression since Riley’s lawsuit addressed the Fourth
Amendment right against illegal and warrantless searches. Nonetheless, I feel
that this case is important because it sets a precedent for considering the
value of digital content that people store on their mobiles.

Conclusion

Riley
presented an issue related to the Fourth Amendment before the highest federal
court in the U.S. The petitioner wanted the judiciary to stop the utilization
of evidence obtained from his phone during a warrantless search since he felt
that the action infringed his rights. The Supreme Court ruled in favor of Riley
by concluding that the police agency should have obtained a warrant before
subjecting the cell phone to a search. Similarly, I support this decision
because it complies with the stipulations of the U.S. Constitutions and other
applicable laws and expands the freedom of expression.