The Supreme Court of Arkansas has held in Gulley v. State of Arkansas that police do not need a warrant to obtain the content of text messages, and that a mere subpoena will suffice. Other courts have recently held that the Fourth Amendment in fact requires a search warrant for any communications content. And, of course, the Stored Communications Act (SCA) requires the government to get a warrant if it wants to obtain the contents of communications stored by an electronic communication service provider for 180 days or less. But the court here avoided the SCA issue on the ground that it was not raised at trial. And it held that the Fourth Amendment simply requires that the subpoena power not be abused, without considering whether a person has any reasonable expectation of privacy in his electronic communications. This case demonstrates once again how uneven courts are in their understanding of how basic constitutional concepts apply in the digital age.