Messages within pagers seized from suspects during an arrest may provide incriminating information or valuable leads. Courts have not held that activating a pager to obtain messages sent to it is not an interception of a communication under Title III, the Federal electronic surveillance law, because the transmission of the communication ceases when the pager receives the communication. Courts first determine whether the party challenging the search of the pager had a reasonable expectation of privacy in the pager's contents. If the party is found to have an expectation of privacy, courts next consider whether retrieving the messages within the pager was reasonable under the Fourth Amendment. Most courts have concluded that electronic surveillance laws do not govern the search of pagers incident to arrest. However, it is likely at some point that the delay between the arrest and the search of the pager would render the search unreasonable. Photographs and reference notes