CA7: SW to seize a cell phone implicitly carries authority to search it

“Cosby argues that the district court erred in denying his motion to suppress evidence seized from his cell phone. He argues that the warrant, though authorizing seizure of the device, did not authorize the agents to view its contents. But Cosby recognizes that his argument is foreclosed by this court’s decision in United States v. Fifer, 863 F.3d 759 (7th Cir. 2017), on which the district court relied. Fifer held that a state warrant that explicitly authorized the police to seize an electronic device additionally ‘implicitly authorized them to search those devices as well.’ Id. at 766. Cosby’s citation to out of circuit precedent is unavailing.” United States v. Cosby, 2019 U.S. App. LEXIS 13907 (7th Cir. May 9, 2019).