SEARCH OF A VEHICLE’S ELECTRONIC MEMORY: Due to the increased sophistication of automobile electronics, criminal investigators should consider establishing probable cause for a search of the automobile’s electronic memory prior to the execution of a search warrant on a suspect’s vehicle. Newer vehicles are commonly installed with Bluetooth technology which allows cellular telephones to link with the automobile and allow for hands free operation of the phone. Bluetooth technology can download or synchronize the cellular handset’s contact list to the vehicle’s electronic memory storage. The contact list/phonebook capacity varies from just over 100 to upwards of 10,000 entries according to the particular system installed. These entries can be stored and accessible even after the phone is no longer linked to the vehicle and after the ignition is disengaged. If a navigation system is also installed in the vehicle, the contact list may have addresses or GPS coordinates associated with the phone number entries. Although Bluetooth technology allows for twoway exchange of data, the Bluetooth Profile implemented in vehicle systems does not allow phonebooks downloaded from one cellular handset to be uploaded to another handset or device. Thus, agents executing a search warrant should be prepared to manually record searched entries. The current trend indicates Bluetooth technology will become more common in vehicles as a means of operating a cellular phone while driving. California, Connecticut, New Jersey, New York, Oregon, Washington State, the District of Columbia, and the U.S. Virgin Islands have all adopted laws banning drivers from talking on handheld cellular phones while driving, with momentum building for the passage of laws in other states. Whereas a few years ago, only high end vehicles from luxury manufacturers provided Bluetooth technology as an option, many manufacturers offer Bluetooth technology as a factory installed option on lower end models such as the Ford Focus. MSNBC reports that by 2013, approximately 30 percent of all new car sales will be purchased with handsfree features onboard. Numerous suppliers and manufacturers offer aftermarket kits to install the technology in vehicles lacking factory installation and the kits are selling in the millions. The exploitation of this feature presents investigators with a possible wealth of investigative evidence to be obtained from target’s vehicle by utilizing a search warrant to access the vehicle’s electronic memory. The search of a vehicle’s electronic systems for navigation information or telephone, address, or calendar information stored in a vehicle via a Bluetooth connection implicates the 4th Amendment. A search warrant or an exception to the search warrant requirement, such as exigent circumstances, search incident to arrest, or the vehicle exception may be required to conduct the search.