Georgia Case on Searching Cell Phones Incident to Arrest

State court decisions from other southeastern states seem to carry a bit more weight as persuasive authority than do cases from jurisdictions that are farther afield. Therefore, I thought I'd summarize a recent decision by the Georgia Court of Appeals about searching cell phones incident to arrest. The case is Hawkins v. State. A police officer lawfully came into possession of a drug dealer's phone, on which he received a text message from the defendant asking whether the drug dealer had any drugs for sale. The officer posed as the drug dealer and negotiated a sale. The parties agreed to meet at a restaurant to complete the deal. When the defendant arrived at the restaurant, officers were able to identify her as the buyer because (1) they saw her texting, and (2) the drug dealer's phone promptly received a message saying, in effect, "I'm here." They arrested the defendant, apparently in her car. They then searched the car incident to arrest; in the defendant's purse, they found her cell phone. They searched the phone, finding the text messages between her and the drug dealer's phone. The defendant moved to suppress. The trial judge denied the motion, and the defendant appealed on an interlocutory basis, which is apparently allowable under Georgia procedure. The appellate court affirmed. The majority determined that the search was permitted under the prong of Arizona v. Gant that allows a vehicle to be searched incident to arrest "when it is reasonable to believe that evidence of the offense [...]