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Accident Phone Evidence Checklist
A checklist for plaintiff and defense attorneys, insurance investigators, and accident reconstructionists working a case where a driver's phone use is at issue.
What's in this checklist
A checklist to preserve, request, and analyze mobile device evidence to determine whether a driver was distracted at the time of a collision.
Preview · Section 1
Preserve immediately (the clock starts at the crash)
Send a preservation letter to the opposing driver and their carrier identifying the specific phone(s) by make, model, and number if known.
Preserve the carrier's call detail records (CDRs). Most carriers purge or summarize after 12–18 months.
Preserve the driver's cloud accounts: iCloud, Google, the device manufacturer's cloud backup.
▣ 24 more items, 4 more sections
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Section 1
Section 1: Preserve immediately (the clock starts at the crash)
Send a preservation letter to the opposing driver and their carrier identifying the specific phone(s) by make, model, and number if known.
Preserve the carrier's call detail records (CDRs). Most carriers purge or summarize after 12–18 months.
Preserve the driver's cloud accounts: iCloud, Google, the device manufacturer's cloud backup.
If the driver was on the job, preserve the employer's MDM logs, telematics (Samsara, Geotab, Lytx), and dashcam footage.
Photograph the phone in its post-crash state before it is moved, charged, or unlocked.
Section 2
Section 2: What to request in discovery
Forensic image of the phone (not screenshots, not a manual review).
Cloud backup files (iCloud backup, Google Takeout) covering the 24 hours before and after the collision.
Carrier records: voice CDRs, SMS/MMS detail, and cellular data session logs for the relevant window.
Application data for every app installed: maps, music streaming, messaging, social media, dating apps, games.
CarPlay or Android Auto pairing history and Bluetooth connection logs.
Driving-detection or safety-app data (the iPhone "Focus while driving" mode, Life360, Apple/Google location history).
Section 3
Section 3: What the forensic analysis should answer
Was the screen on at the moment of impact?
Was a specific app in the foreground? Which one, and what was it doing (typing, scrolling, video playing)?
Was the phone unlocked? When was it last unlocked relative to the collision?
Was a call active? Hands-free or handheld?
Was the phone sending or receiving text messages, app notifications, or data?
What did the phone's accelerometer and gyroscope record at the moment of impact?
What did the phone's GPS log for speed, heading, and location?
Section 4
Section 4: Common evidentiary pitfalls
Carrier records show *attempted* connections, not what the user actually did. Phone artifacts are required to prove use.
iMessage and WhatsApp do not appear in carrier records; only the phone or cloud backup shows them.
An unlock without app activity may still be relevant. It proves the driver looked at the phone.
Time-zone drift between phone, carrier, and dashcam can shift events by hours if not normalized.
An iPhone "Driving Focus" mode that was enabled but bypassed is highly probative.
Section 5
Section 5: Authentication for trial
Hash-verified forensic image, with chain of custody documented from collection forward.