phone's security features, apart from any active attempt by a defendant or his associates to conceal or destroy evidence upon arrest." He then argued that a warrantless search is unlikely to make much of a difference. Furthermore, Roberts argued that cell phones differ both quantitatively and qualitatively from other objects in a person's pocket: Modern cell phones are not just another technological convenience. With all they contain and all they may reveal, they hold for many Americans “the privacies of life". The fact that technology now allows an individual to carry such information in his hand does not make the information any less worthy of the protection for which the Founders fought. Concurring opinion Justice Samuel Alito wrote an opinion concurring in the judgment, noting that "we should not mechanically apply the rule used in the predigital era to the search of a cell phone. Many cell phones now in use are capable of storing and accessing a quantity of information, some highly personal, that no person would ever have had on his person in hard-copy form." However, in trying to find a balance between law enforcement and privacy issues, Alito expressed concern that the majority opinion would create anomalies: "Under established law, police may seize and examine [hard copies of information] in the wallet without obtaining a warrant, but under the Court's holding today, the information stored in the cell phone is out." Alito further suggested that Congress or state legislatures may need to consider new laws that draw "reasonable distinctions based on categories of information or perhaps other variables", otherwise "it would be very unfortunate if privacy protection in the 21st century were left primarily to the federal courts using the blunt instrument of the Fourth Amendment". Impact The Supreme Court's ruling in Riley v. California was generally praised for addressing the challenges presented by new technologies, but with mixed reviews concerning its impact on privacy law and police procedure. Some commentators believed that the ruling allowed courts to adapt older search warrant rules for modern behaviors in which people store great amounts of private information on their phones; though others found the ruling to be too narrow and focused only on the types of flip phones and smart phones used during that time period, thus creating an uncertain precedent for future technological developments. Therefore, the ruling may be more useful for matters of police procedure rather than