before the riley case, the court had explored variations on the "chime" theme, considering police searches of various items individuals had close at hand when arrested, and the justices were prepared to look into the seizure of cell phones "incident to arrest". lower courts were in dispute on whether the fourth amendment allows the police to search the digital contents of such a phone, without first getting a warrant. it was unclear whether, or how much, difference it would make to the court, but the two cases it chose to review on that question involved different versions of cellphones: the traditional "flip-phone", which is very old, as opposed to the more modern "smartphone", which potentially holds much more data about the user.