Defendant’s using his cell phone to arrange a drug transaction justified a search warrant for it. If firearms are “tools of the trade,” then so are cell phones. United States v. Eggerson, 2021 U.S. App. LEXIS 16823 (8th Cir. June 7, 2021):
We note first that cell phones are now so widespread as to be ubiquitous. See Riley, 573 U.S. at 395. There is no reason to suspect that drug dealers are any less likely than regular people to have and use a cell phone. See, e.g., United States v. Williams, 976 F.3d 807, 810 (8th Cir. 2020); United States v. Denson, 967 F.3d 699, 703 (8th Cir. 2020). In fact, given the nature of the business and the need for easy and instantaneous communication with buyers, drug dealers may be even more likely to use cell phones. If firearms are “tool[s] of the [drug] trade,” as we have often said, there is little reason to believe that cell phones are not. United States v. Fuentes Torres, 529 F.3d 825, 827 (8th Cir. 2008) (citation omitted).