Phones are not luggage, but US courts basically treat them that way by allowing agencies such as ICE & CBP to search people's phones at the border *without suspicion* In no world does CBP need access to all of travelers' private photos, documents, communication etc. to make an entry determination.
CA2 says federal government can conduct suspicionless searches of any international traveler's cellphones - even U.S. citizens! - upon arrival at the border. The 2nd Circuit covers JFK Airport. Biden judge concurs in the judgment to say WTF! storage.courtlistener.com/pdf/2026/09/...