The Massachusetts Supreme Judicial Court in State v. Phifer last month decided whether an officer can conduct a warrantless search of a suspect’s cellular telephone after his arrest. Of course, there is a warrant requirement in the State and Federal Constitutions but a search incident to arrest has long been an exception to the warrant clause. The officers had probable cause to believe that the cell phone was involved in the drug deal because they had seen the defendant using it just before the drugs were passed to another person. Police also testify that based on their experience, cell phones are commonly used in the drug trade.