Warrantless cellphone search OK in California, but not in Ohio

Earlier today I wrote about the decision by the California Supreme Court to permit warrantless searches of cell phones in searches incident to a lawful arrest.  Here is a case from December 2009 from the Ohio Supreme Court which has similar facts but the court ultimately came to a different conclusion.  With conflicting rulings from two separate state supreme courts (and a federal district court), the issue will likely to get more attention from the Supreme Court.

State v. Smith