although possible evidence stored on a phone may be destroyed with either remote wiping or data encryption, roberts noted that is "the ordinary operation of a phone's security features, apart from any active attempt by a defendant or his associates to conceal or destroy evidence upon arrest." he then argues that a warrantless search is unlikely to make much of a difference: cell phone data would be vulnerable to remote wiping from the time an individual anticipates arrest to the time any eventual search of the phone is completed... likewise, an officer who seizes a phone in an unlocked state might not be able to begin his search in the short time remaining before the phone locks and data becomes encrypted. roberts then cites several common examples to turn off or prevent the phone's security features.