State v. Granville
Texas Court of Criminal Appeals
423 S.W.3d 399 (2014)
Anthony Granville (defendant), a student, was arrested for causing a disturbance on a school bus, and his cell phone was placed in the jail's property room. After a school resource officer learned Granville may have photographed another student in a restroom, the officer retrieved the phone from jail storage and searched its contents without a warrant, discovering the photo. Granville was charged with improper photography and moved to suppress the phone evidence as a Fourth Amendment violation; the trial court granted the motion, and the court of appeals affirmed.
Whether, under the Fourth Amendment, police may search the contents of an individual's cell phone stored in jail property after arrest, without obtaining a warrant.