GA: Cell phone search was harmless because of another legally searched phone

While defendant was being interviewed by the police, his cell phone was on the table getting text messages from “Head.” The officer opened the phone to see Head’s number. Whether the search of the phone was lawful or not doesn’t matter because it’s harmless beyond a reasonable doubt. “Pretermitting whether Riley required the police to obtain a search warrant for Campbell’s cell phone, we conclude that any error by the trial court in denying Campbell’s motion to suppress the contents of his phone was harmless.” Campbell v. State, 2016 Ga. App. LEXIS 246 (April 27, 2016).

There was reasonable suspicion on the totality that defendant was involved in an armed robbery. He was picked up by a truck driver after wrecking his car, and the car was linked to the robbery. State v. Ruiz, 2016 Ariz. App. LEXIS 73 (April 27, 2016).*