White Collar Roundup - December 2016

The Plain View Doctrine in the Age of the iPhone

U.S. District Judge Kevin McNulty of the District of New Jersey ruled in United States v. Ravelo that agents lawfully searched defendant Keila Ravelo's iPhone, which they seized at the time of her arrest. When Ravelo was a partner at a law firm in New York, the government began to investigate her for fraud and tax evasion. Government agents obtained an arrest warrant, which they executed at Ravelo's home. During her arrest, Ravelo picked up her iPhone and typed in a code to unlock it. One of the agents told Ravelo she could not make any calls, but would allow Ravelo to obtain her attorney's phone number and provide it to her son. Without then obtaining the number, Ravelo locked the phone. The agent then picked up the phone and asked Ravelo for the code to allow the agent to provide the attorney's phone number to Ravelo's son. Ravelo gave the agent the code and the agent unlocked the phone. Upon doing so, the screen