United States v. Robinson
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Supreme Court of Washington declined to adopt Robinson's rule under its own constitution, as noted separately below. The Supreme Court of Ohio, the First Circuit, the Supreme Court in Riley v. California, and the Tenth Circuit confined Robinson when addressing cell-phone data or containers not part of an arrestee's clothing.
3,485 later cases cite United States v. Robinson; 126 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on United States v. Robinson?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court of Ohio declined to extend Robinson's physical-container rule to cell-phone data and required a warrant before searching a phone's contents incident to arrest.
State v. Smith · Supreme Court of Ohio · filed
We therefore hold that because a cell phone is not a closed container, and because an individual has a privacy interest in the contents of a cell phone that goes beyond the privacy interest in an address book or pager, an officer may not conduct a search of a cell phone’s contents incident to a lawful arrest without first obtaining a warrant.
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The First Circuit declined to extend Robinson's categorical search authority to data stored on a cell phone seized from an arrestee.
United States v. Wurie · First Circuit · filed
We therefore hold that the search-incident-to-arrest exception does not authorize the warrantless search of data on a cell phone seized from an arrestee’s person, because the government has not convinced us that such a search is ever necessary to protect arresting officers or preserve destructible evidence.
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The Supreme Court expressly declined to extend Robinson to cell-phone data and held that officers generally must obtain a warrant before searching it.
Riley v. California · Supreme Court of the United States · filed
We therefore decline to extend Robinson to searches of data on cell phones, and hold instead that officers must generally secure a warrant before conducting such a search.
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The Tenth Circuit confined Robinson's categorical rule to an arrestee's person, clothing, and containers concealed within clothing, leaving a visible handheld purse to Chimel's case-specific immediate-control test.
United States v. Knapp · Tenth Circuit · filed
To the extent the government suggests a construction that includes more than the arrestee’s immediate person, worn clothing, or containers concealed within her clothing, we decline to adopt it. ... The better formulation, we believe, would be to limit Robinson to searches of an arrestee’s clothing, including containers concealed under or within her clothing.
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