Case 4:16-cr-40070-KES Document 262 Filed 02/17/17 Page 6 of 11 PageID #: 898 As the Supreme Court explained in Riley, however, cell phone data is not the same as physical evidence. In Riley, the issue before the Supreme Court was whether cell phones could be searched incident to arrest like other physical objects found on arrestees. Riley v. California, 134 S. Ct. 2473, 2482 (2014). The court held that because cell phones contain immense amounts of personal information about people’s lives, they are unique, and law enforcement “officers must generally secure a warrant before conducting such a search.” Id. at 2485. This court reaches a similar conclusion. As explained by Magistrate Judge Duffy, “[t]he chief evil [that] the Fourth Amendment was intended to address was the hated ‘general warrant’ of the British crown.” Docket 251 at 10 (citing Payton v. New York, 445 U.S. 573, 583-84 (1980)). If the scope of the Beadle County warrant was not limited to the Hurron Police Department’s counterfeiting investigation, the search warrant would have been an invalid “general warrant.” Id. at 16 (citations omitted). As explained by Magistrate Judge Duffy, “[t]he conclusion is inescapable: Agent Fair should have applied for and obtained a second warrant [that] would have authorized him to search Mr. Hulscher’s cell phone data for evidence of firearms offenses.” Id. at 32 (citations omitted). The government argues that this conclusion is “impractical and is contrary to the nature of police investigations and collaborative law enforcement among different agencies.” Docket 255 at 1-2. The government’s position, however, overlooks the ultimate touchstone of the Fourth Amendment: reasonableness. Riley, 134 S. Ct. at 2482. According to the 6