Ohio holds today (4-3) that a cell phone search requires a warrant without exigent circumstances. Therefore, it was not subject to a search incident. Today’s cell phones are analogous to a computer. State v. Smith, 2009 Ohio 6426 (December 15, 2009).
FourthAmendment blog reports. Seems there ought to be similar results for a military search and that the fruits of a warrantless search should similarly be excluded at court-martial.