Read the following excerpt from a US court opinion:
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of a cell phone incident to arrest. See, e.g., Hawkins v. State, 290 Ga. 785, 723 S.E.2d 924, 926 (2012) (upheld search of text messages that was limited “as much as is reasonably practicable by the object of the search”); Commonwealth v. Phifer, 463 Mass. 790, 979 N.E.2d 210, 216 (2012) (upheld search of recent call list). On the other hand, a smaller number of courts, including one circuit court, several state supreme courts, and several district courts, have now rejected the notion that the contents of a cell phone are susceptible to search upon arrest, particularly in circumstances where the phone has been removed from the arrestee’s person by the police. See, e.g., United States v. Wurie, 728 F.3d 1 (1st Cir.2013), cert. granted, — U.S. —, 134 S.Ct. 999, 187 L.Ed.2d 848 (2014) ; United States v. Mayo, No. 2:13-cr-48, 2013
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What is the most suitable continuation to the opinion? Your options are:
A. holding that warrantless searches of cell phones incident to arrest should not be allowed because such searches cannot be justified by officer safety or the preservation of evidence given the privacy implications inherent in cell phone data searches
B. holding a person may consent to warrantless searches as a condition of a suspended sentence
C. holding a warrantless search of cell phone contents did not exceed permissible scope of search incident to arrest
D. holding that while law enforcement officers properly separated and assumed possession of a cell phone from arrestees person during the search incident to arrest a warrant was required before the information data and content of the cell phone could be accessed and searched by law enforcement
E. holding that consensual suspicionless searches of government employees personal belongings in the workplace were searches even though refusal to consent carried no criminal penalty and the searches were not for law enforcement purposes
Reply with [A, B, C, D, E] only.