With no explanation, chose the best option from "A", "B", "C" or "D". can reveal the location where a photograph was taken. Although the use of such smartphones is now pervasive, the law is unsettled as to whether the data in an arrestee’s smart-phone may be searched, in whole or in part, incident to arrest. To date, neither, the Supreme Court nor the Sixth Circuit Court of Appeals (“Sixth Circuit”) has addressed whether a warrantless search incident to arrest of the data contained in the memory of a smartphone found on an ar-restee’s person violates the Fourth Amendment. On the one hand, a significant majority of the circuit courts of appeals to reach this issue have concluded that at least some search of the data on a cell phone found on an arrestee’s person is permissible. See, e.g., United States v. Rodriguez, 702 F.3d 206, 209-10 (5th Cir.2012) (<HOLDING>); United States v. Flores-Lopez, 670 F.3d 803,

A: holding that while law enforcement officers properly separated and assumed possession of a cell phone from arrestees person during the search incident to arrest a warrant was required before the information data and content of the cell phone could be accessed and searched by law enforcement
B: holding that while search incident to arrest could not justify search in that case probable cause plus exigency justified search
C: holding a warrantless search of cell phone contents did not exceed permissible scope of search incident to arrest
D: holding seizure of arrestees cell phone lawful but finding the fourth amendment requires a warrant to perform a forensic search of the lawfully seized cell phone
C.