People v. Rafael C. (In re Rafael C.)

*1290 Rafael C. (Minor) appeals from an order of the juvenile court sustaining a petition filed pursuant to Welfare and Institutions Code section 602. 1 The petition arose from an incident at Minor's high school in which a firearm was discovered on campus. School administrators suspected Minor's involvement, and in the course of questioning him, they seized and searched his cell phone. Interspersed with the text messages on the phone were a number of digital images, including a photograph of Minor holding what appeared to be the firearm found on campus. When the prosecution sought to use these images as evidence in the proceeding below, Minor unsuccessfully moved to suppress them. The juvenile court found Minor had possessed an assault weapon, and it declared him a ward of the juvenile court.

On appeal, Minor challenges the denial of his motion to suppress. In the published portion of our opinion, applying the twofold test established in *1291 New Jersey v. T.L.O. (1985) 469 U.S. 325 , 105 S.Ct. 733 , 83 L.Ed.2d 720 ( T.L.O. ), we conclude the search of Minor's cell phone was reasonable. Considering all the circumstances, the juvenile court properly found the search was justified…