. >> how about a plainview announces?rn on the phone, see if there's been a telephone call within a reasonable amount of time of the arrest or any message that was sent at the time of arrest. that's sort of a plain view situation. it would take care of your person with a picture of him or herself with the guns. it would take care of the call to the confederate. it would take care of the imminent destruction of the phone. >> justice sotomayor, i'm not entirely sure how to articulate that principle, but if it fits within the crime of arrest plus identity principle, and i think it would be a reasonable fallback position. if i could reserve the balance of my time. >> thank you, counsel. ms. mizner. >> mr. chief justice, and may it please the court. i'd like to first talk about the encryption that we've been discussing. it's not an issue in this case. it was not an issue in riley. it was not litigated below. the government has just now said that there are a lot of phones arriving at a lab in a locked state, but do we know whet