If a cell phone is seized incident to arrest, may an officer search its digital contents on scene without a separate digital-data warrant?

If a cell phone is seized incident to arrest, may an officer search its digital contents on scene without a separate digital-data warrant?

• A. Yes, all contents may be searched
• B. Yes, if the phone is unlocked
• C. Only photos can be viewed without a warrant
• D. No, generally a separate warrant is required for most digital data

Answer: (D)