Riley v. California Case Brief

Facts of the case

David Leon Riley belonged to the Lincoln Park gang of San Diego, California. On August 2, 2009, he and others opened fire on a rival gang member driving past them. The shooters then got into Riley’s Oldsmobile and drove away. On August 22, 2009, the police pulled Riley over driving a different car he was driving on expired license registration tags. Because Riley’s driver’s license was suspended, police policy required that the car be impounded. Before a car is impounded, police are required to perform an inventory search to confirm that the vehicle has all its components at the time of seizure, to protect against liability claims in the future, and to discover hidden contraband. During the search, police located two guns and subsequently arrested Riley for possession of the firearms. Riley had his cell phone in his pocket when he was arrested, so a gang unit detective analyzed videos and photographs of Riley making gang signs and other gang indicia that were stored on the phone to determine whether Riley was gang affiliated. Riley was subsequently tied to the shooting on August 2 via ballistics tests, and separate charges were brought to include shooting at an occupied vehicle, attempted murder, and assault with a semi-automatic firearm.Before trial, Riley moved to suppress the evidence regarding his gang affiliation that had been acquired through his cell phone. His motion was denied. At trial, a gang expert testified to Riley’s membership in the Lincoln Park gang, the rivalry between the gangs involved, and why the shooting could have been gang-related. The jury convicted Riley on all three counts and sentenced to fifteen years to life in prison. The California Court of Appeal, Fourth District, Division 1, affirmed.

CONCLUSION

The U.S. Supreme Court unanimously held that the police officers generally could not, without a warrant, search digital information on the cell phones seized from the defendants as incident to the defendants’ arrests. While the officers could examine the phones’ physical aspects to ensure that the phones would not be used as weapons, digital data stored on the phones could not itself be used as a weapon to harm the arresting officers or to effectuate the defendants’ escape. Further, the potential for destruction of evidence by remote wiping or data encryption was not shown to be prevalent and could be countered by disabling the phones. Moreover, the immense storage capacity of modern cell phones implicated privacy concerns with regard to the extent of information which could be accessed on the phones.

  • Advocates: –
  • Petitioner: David Leon Riley
  • Respondent: State of California
  • DECIDED BY:Roberts Court
  • Location: California Fourth District Court of Appeal
Citation: 573 US 373 (2014)
Granted: Jan 17, 2014
Argued: Apr 29, 2014
Decided: Jun 25, 2014
Riley v. California Case Brief