search of an electronic device presumably “could encompass things like text messages, emails, or photographs.” United States v. Wurie, 728 F.3d 1, 7 (1st Cir.2013), cert. granted, — U.S.-, 134 S.Ct. 999, 187 L.Ed.2d 848 (2014) (citations omitted). Given that “individuals today store much more personal information on their cell phones than could ever fit in a wallet, address book, [or] briefcase,” the court in Wurie expressed its concern that a warrantless search of cell phone data incident to an arrest would be akin to the writs of assistance used by “customs officers in the early colonies ... to rummage through homes and warehouses, without any showing of probable cause linked to a particular place or item sought.” Wurie, 728 F.3d at 9; see also Flores-Lopez, 670 F.3d at 805 (<HOLDING>); United States v. Lucas, 640 F.3d 168, 178
holding seizure of arrestees cell phone lawful but finding the fourth amendment requires a warrant to perform a forensic search of the lawfully seized cell phone holding a warrantless search of cell phone contents did not exceed permissible scope of search incident to arrest recognizing that a modern cell phone is a computer and not just another purse or address book so that the potential invasion of privacy in a search of a cell phone is greater than in a search of a container in a conventional sense holding that the permissible scope of a search incident to arrest includes the contents of a cell phone found on the arrestees person holding that while law enforcement officers properly separated and assumed possession of a cell phone from arrestees person during the search incident to arrest a warrant was required before the information data and content of the cell phone could be accessed and searched by law enforcement