Concurring Opinion: Justice Roberts: The used of the Balancing Test seen used in United States v. Robinson determines that the officers were not justified in searching the phones contents. The advancement of modern technology creates a difficult area of ensuring privacy, in most cases the Balancing Test is used to determine legality. The officers were neither acting to ensure safety of other officers, nor were they protecting the destruction of evidence. Scope of privacy continues to get more complicated with advancement of technology, when smartphones can track movement, search the internet, and upload to storage clouds. The search of cell phones should be restricted to situations that contain issues in officer safety or evidence of crime
