{"id":64455,"date":"2026-07-13T19:19:50","date_gmt":"2026-07-14T00:19:50","guid":{"rendered":"https:\/\/fourthamendment.com\/?p=64455"},"modified":"2026-07-13T20:22:15","modified_gmt":"2026-07-14T01:22:15","slug":"ca4-cell-phone-border-search-doesnt-require-individualized-suspicion","status":"publish","type":"post","link":"http:\/\/fourthamendment.com\/?p=64455","title":{"rendered":"CA4: Cell phone non-forensic border search doesn&#8217;t require individualized suspicion"},"content":{"rendered":"\n<p>\u201cBorder searches do not require a warrant to be reasonable. And if a border search is routine, individualized suspicion is not required either. But law enforcement may not conduct a nonroutine border search without individualized suspicion. Under our precedent, forensic searches of cell phones are nonroutine. But what about manual searches? Today, we join all our sister circuits that have addressed this issue in holding that manual searches of cell phones at the border are routine and thus do not require individualized suspicion.\u201d CSAM was found. <a href=\"https:\/\/www.ca4.uscourts.gov\/opinions\/254239.P.pdf\">United States v. Cardozo<\/a>, 2026 U.S. App. LEXIS 20419 (4th Cir. July 13, 2026).<\/p>\n\n\n\n<p>Defendant was subjected to two traffic stops. Between them, officers saw and suspected drug deliveries. The second stop was objectively reasonable, and it was the dog sniff was with reasonable suspicion developed after the first stop. United States v. Drayton, 2026 U.S. App. LEXIS 20380 (8th Cir. July 13, 2026).*<\/p>\n\n\n\n<p>Defendant was observed doing drug deals in the parking lot outside his apartment. The officers reasonably inferred that he had drugs in his apartment. Moreover, the good faith exception applies. United States v. Gray, 2026 U.S. App. LEXIS 20290 (6th Cir. July 9, 2026).*<\/p>\n","protected":false},"excerpt":{"rendered":"<p>\u201cBorder searches do not require a warrant to be reasonable. And if a border search is routine, individualized suspicion is not required either. But law enforcement may not conduct a nonroutine border search without individualized suspicion. Under our precedent, forensic &hellip; <a class=\"more-link\" href=\"http:\/\/fourthamendment.com\/?p=64455\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[5,27,11,38,20,35],"tags":[],"class_list":["post-64455","post","type-post","status-publish","format-standard","hentry","category-cell-phones","category-dog-sniff","category-good-faith-exception","category-nexus","category-probable-cause","category-reasonable-suspicion"],"_links":{"self":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64455","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=64455"}],"version-history":[{"count":3,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64455\/revisions"}],"predecessor-version":[{"id":64458,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64455\/revisions\/64458"}],"wp:attachment":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=64455"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=64455"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=64455"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}