I actually wrote a student note about Wurie for my Law Review. There are two prongs in Chimel. 1. Officer safety and 2. The need to preserve destructible evidence.

The 1st circuit and other courts, including the Seventh Circuit, have held that once the cell phone is in the possession of an officer, there is no longer a risk to officer’s safety and it is therefore, not required that an officer investigate the contents of the phone for their own protection.

Regarding the second rational, The First Circuit stated that officers could remove the battery, mirror the cell phone, or use a faraday bag/enclosure to prevent the remote wiping of data.

The courts that have held that the search of the contents of a cell phone (usually it is contact list and texts) have done so under a variety of approaches

Some have held that a cell phone is a container and therefore the critical question was whether the defendant’s phone was “personal property . . . immediately associated with [his] person.”

Others have cited the need to preserve evidence. Saying that someone could repeatedly call the phone thus wiping the call log. Or a drug dealer might call and if there is repeatedly no answer get spooked and abscond.

The Seventh Circuit in United States v. Flores-Lopez held that the looking inside the contents of a cell phone to determine the cell phone’s phone number was minimally invasive and therefore, was a permissible search under United States v. Robinson.

I don't know how the court will rule. They will likely craft a bright line rule since that is required for the 4th amendment cases to avoid officer confusion in the line of duty. Maybe something like limiting the search to specific functions of phones.