Whether an officer must expressly state that he is seeking consent for a forensic, not just a manual, search of a cell phone

QUESTION PRESENTED FOR REVIEW During a custodial interrogation, a police detective asked for the password to Danny Williams’ cell phone, which had been seized incident to Williams’ arrest. Williams complied and provided the password. He and the detective then looked at portions of the phone’s content, but Williams specifically directed the detective not to look at other portions. After the interrogation, the detective had a full forensic search conducted on the entire phone. Over William’s objection that limited consent to a manual search could not be construed as consent to a forensic search, evidence extracted during the forensic search was admitted at his trial. The question presented is whether an officer must expressly state that he is seeking consent for a forensic, not just a manual, search of a cell phone.