A warrant must describe with particularity what data is to be collected - a general search and seizure will not stand. In Riley v. California, Riley’s cell phone was searched without a warrant. The Supreme Court ruled that a warrant is required to search a cell phone and that the data to be collected must also be specified in light of the excessive amount of data stored in cell phones, and the probable cause requirement for a search by law enforcement. Even if the “plain view” doctrine is evoked, data from cell phones may not be considered in plain view because Cellebrite, the program most law enforcement agencies use to download phone content, requires the selection of specific data to download and, therefore, that data is not actually in plain view.