Several district courts in other circuits have held that officers may search the contents of a cell phone seized during a traffic stop as long as there is probable cause to believe the phone contained evidence of a crime. See United States v. Garcia-Aleman, 2010 WL 2635071 (E.D. Tex., June 9, 2010), report and recommendation adopted, 2010 WL 2635073 (E.D. Tex. June 30, 2010); United States v. Monson-Perez, 2010 WL 889833 (E.D. Mo. March 8, 2010); United States v. James, 2008 WL 1925032 (E.D. Mo. April 29, 2008), aff'd in part on other grounds, 618 F.3d 832 (8th Cir. 2010); United States v. Ball, 2005 WL 2649496 (W.D. Mo. Oct. 14, 2005), aff'd on other grounds, 499 F.3d 890 (8th Cir. 2007), cert. granted, judgment vacated on other grounds, 129 S. Ct. 2049 (2009); United States v. Cole, 2010 WL 3210963 (N.D. Ga. Aug. 11, 2010). The court finds, based on the record at the evidentiary hearing, that there was probable cause to believe the cell phones contained evidence of a crime.

I do note, however, that at least two courts have determined that a cell phone or similar device found during a vehicle search may itself be searched. United States v. Ball, 2005 WL 2649496 (W.D. Mo. Oct. 14, 2005), at *4; United States v. Woodley, 2005 WL 3132205 (E.D.Mich. Nov. 22, 2005), at *5-*8 (search and seizure of two-way pager found in searched vehicle justified under "automobile exception" to warrant requirement).