 A common law rule from Great Britain permits searches incident to an arrest without a warrant. This rule has been applied in American law, and has a lengthy common law history. The justification for such a search is to prevent the arrested individual 1. ) from destroying evidence or 2. ) using a weapon against the arresting officer by disarming the suspect. The U.S. Supreme Court ruled that "both justifications for the search-incident-to-arrest exception are absent and the rule does not apply", when "there is no possibility" that the suspect could gain access to a weapon or destroy evidence. In Trupiano v. United States (1948), the Supreme Court held that "a search or seizure without a warrant as an incident to a lawful arrest has always been considered to be a strictly limited right. It grows out of the inherent necessities of the situation at the time of the arrest. But there must be something more in the way of necessity than merely a lawful arrest." In United States v. Rabinowitz (1950), the Court reversed Trupiano, holding instead that the officers'opportunity to obtain a warrant was not germane to the reasonableness of a search incident to an arrest. Rabinowitz suggested that any area within the "immediate control" of the arrestee could be searched, but it did not define the term. In deciding Chimel v. California (1969), the Supreme Court elucidated its previous decisions. It held that when an arrest is made, it is reasonable for the officer to search the arrestee for weapons and evidence. However, in Riley v. California (2014), the Supreme Court ruled unanimously that police must obtain a warrant to search an arrestee's cellular phone. The Court said that earlier Supreme Court decisions permitting searches incident to an arrest without a warrant do not apply to "modern cellphones, which are now such a pervasive and insistent part of daily life that the proverbial visitor from Mars might conclude they were an important feature of human anatomy," and noted that US citizens' cellphones today typically contain "a digital record of nearly every aspect of their lives — from the mundane to the intimate."
