Officer Morris Was Working as an Undercover Narcotics Officer

Officer Morris was working as an undercover narcotics officer. His team carefully planned a drug buy and obtained a voice transmitter which was taped to Officer Morris's chest. Officer Morris went to the park where he had previously observed drugs being sold. He approached Ned and, using street terms, asked to purchase one ounce of cocaine. Ned replied, "I can give you some now and the rest later." As Officer Morris was getting money out of his pocked Ned pulled out his cell phone and tried to take a picture of Officer Morris. When Officer Morris objected, Ned said, "I just want to be able to identify you when I get my new shipment." Officer Morris immediately alerted his back-up and Ned was arrested. Officer Morris grabbed Ned's phone and looked through his text messages for evidence of who was Ned's supplier. Did Officer Morris need a search warrant to look at the text messages on Ned's phone?

A) Yes, a warrant is required prior to the search of any type of electronic device.
B) Yes, a cell phone is considered a closed container.
C) No, the text messages were the property of the sender not Ned.
D) No, officers are allowed to search cell phones if they are on the person or in the area under the person's immediate control at the time of the arrest.