In Riley v. California, U.S. 134 S. Ct. 2473, 2480, 189 L. Ed. 2d 430 (2014) the Court considered "whether the police may, without a warrant, search digital information on a cell phone seized from an individual who has been arrested." There, officers searched each arrestee's person incident to arrest and found cell phones, which the officers also searched. Id. at, 134 S. Ct. at 2480-81. The Court observed that the two risks identified in Chimel--harm to officers and destruction of evidence--do not exist when the search is of digital data. Id. at, 134 S. Ct. at 2484-85. The Court also reasoned that "a search of the information on a cell phone bears little resemblance to a brief physical search" because "cell phones . . . place vast quantities of personal information literally in the hands of individuals." Id. at, 134 S. Ct. at 2485. Thus, the Court held that "officers must generally secure a warrant before conducting" a search of a phone found on the person of an arrestee. Id. The Court further observed that "digital data stored on a cell phone cannot itself be used as a weapon to harm an arresting officer or to effectuate the arrestee's escape." Id. Officers may seize and secure cell phones to prevent destruction of evidence while they seek a warrant, but "once law enforcement officers have secured a cell phone, there is no longer any risk that the arrestee himself will be able to delete incriminating data from the phone." Id. at, 134 S. Ct. at 2486. The Court rejected the argument that concerns about "remote wiping and data encryption" justified searches of cell phones incident to arrest, stating, "These broader concerns about the loss of evidence are distinct from Chimel's focus on a defendant who responds to arrest by trying to conceal or destroy evidence within his reach." Id. In response to the argument that an arrestee's reduced privacy interests justify the search of a cell phone incident to arrest, the Court stated, "The fact that an arrestee has diminished privacy interests does not mean that the Fourth Amendment falls out of the picture entirely." Id. at, 134 S. Ct. at 2488. Rather, the Court observed that "modern cell phones, as a category, implicate privacy concerns far beyond those implicated by the search of a cigarette pack, a wallet, or a purse." Id. at, 134 S. Ct. at 2488-89. Thus, the Court's "answer to the question of what police must do before searching a cell phone seized incident to an arrest is accordingly simple--get a warrant." Id. at, 134 S. Ct. at 2495.