n U.S. v. Robinson, the U.S. Supreme Court recognized the authority to search a person incident to arrest, including seizing evidence unrelated to the arrest to prevent its destruction or concealment.1 The scope of this authority was further defined in Chimel v. California (the area within the “immediate control”)2 and New York v. Belton (passenger … Continue reading Searching Cell Phones Incident to Arrest: 2009 Update