Does the Fourth Amendment's particularity requirement place any limitations on the search of a cell phone beyond requiring that a search warrant limits law enforcement to searching for evidence of a particular offense and/or to searching within certain broad categories of device data?

The Fourth Amendment ’s warrant requirement protects the contents of cell phones from search by law enforcement. Riley v. California , 573 U.S. 373, 403 (2014) . In the absence of Supreme Court guidance, it is unclear how the Fourth Amendment ’s particularity requirement applies in the context of cell phone searches . Federal circuits and state courts of last resort have reached diametrically opposed conclusions about what limitations the particularity requirement imposes . The question presented is: Does the Fourth Amendment’s particularity requirement place any limitations on the search of a cell phone beyond requiring that a search warrant limits law enforcement 1) to searching for evidence of a particular offense and/or 2) to searching within certain broad categories of device data, such as any messages, any internet history, and any call logs?