broader than items or containers traditionally subject to a search incident to arrest, such as wallets, purses, and briefcase 60 (5th Cir.2007)); United States v. Murphy, 552 F.3d 405, 410-12 (4th Cir.2009) (upholding search of cell phone- as incident to arrest); United States v. Mendoza, 421 F.3d 663, 668 (8th Cir.2005) (seizure and inspection of cell phone valid as a search incident to lawful arrest). Several district courts within this circuit have also reached the conclusion that at least some search of the contents of an arres 13 WL 444764, at *12 (S.D.N.Y. Feb. 5, 2013) (finding á cell phone search unlawful under the seareh-ineident-to-arrest exception in part because the search was “exploratory and rummaging in nature”); Smallwood v. State, 113 So.3d 724, 735-36 (Fla.2013) (<HOLDING>); State v. Smith, 124 Ohio St.3d 163, 920
holding a warrantless search of cell phone contents did not exceed permissible scope of search incident to arrest holding that the permissible scope of a search incident to arrest includes the contents of a cell phone found on the arrestees person 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 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 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