Federal and state courts have chosen to prohibit warrantless cell phone searches entirely. These courts generally rely on the principle that no exigency or need for officer safety exists, or that a delay between the arrest and the search was unreasonable. Further, these courts recognize that the immense amount of personal data stored on cell phones generates a greater expectation of privacy, and, justifies heightened protection under the Fourth Amendment. The District Court of Nebraska concluded that the warrantless search of defendant’s cell phone was unreasonable. The defendant was arrested in 2009 for distributing and conspiring to distribute crack cocaine in 2008. During a search pursuant to his arrest, a cell phone was obtained from the defendant and the officer scanned and saved the contact list on the phone. The court concluded that this search was unjustified because the officer could not reasonably believe that searching the phone would uncover evidence of a crime that allegedly occurred a year earlier. Further, “the phone did not present a risk of harm to officers or appear to be contraband or destructible evidence. The court determined that the search was an invalid search incident to arrest. The District Court for the Northern District of California granted a motion to suppress the warrantless search of the defendants, cell phones. The defendants in this case were arrested for conducting a drug operation inside a residence. At the time of their arrests, no officer searched or seized any of the defendants’ cell phones. Once at the station, the cell phones’ address books and memory were searched by the officers. The court held that the officers did not successfully point to any exception to the warrant requirement to justify the searches and that the searches were “purely investigatory.” Since the search of the phones occurred more than an hour and a half after the arrest, it went “far beyond the original rati