the california supreme court held that seizure of riley's cell phone was lawful due to the fact that the seizure occurred during a "search incident to arrest". the court reasoned that historical precedent had been established from several cases brought to the u.s. supreme court; which that have allowed officers to seize objects under an artiste's control and perform searches of those objects without warrant for the purpose of preserving evidence. in doing so, the court applied the case "people v. diaz", which held that the unwarranted search and seizure of a cell phone on diaz's person was valid. the court, with diaz in mind, contended that only arrest is required for a valid search of an artiste's person and belongings. the court then proceeded to apply "united states v. edwards" to hold that the search was valid despite the fact that it had occurred 90 minutes after arrest. in the edwards case, an arrestee's clothing was seized 10 hours after arrest in order to preserve evidence (paint chips) that might be present on the clothes. given these cases, the state court concluded that the search and seizure of riley's cell phone was valid.