FL1 declines to follow Ohio’s Smith and finds that cell phone is subject to search incident as a “container”

From FourthAmendment.com, where you can read an excerpt from the ruling:

FL1 declines to follow Ohio’s Smith case and holds that a cell phone can be the subject of a search incident. The case surveys many cases on both sides of the issue. Smallwood v. State, 2011 Fla. App. LEXIS 6050 (Fla. 1st DCA April 29, 2011)