The hottest new personal communications device for many Americans during the decade was the cellular phone. Though cellular service had been available since the early 1980s, the sales of cell phones rose as service and equipment became more affordable. For most users, cellular service fell into three categories: 1) portable phones small enough to be carried in a purse or shirt pocket, 2) personal beepers that signaled the holder with a message, and 3) mobile phones that were often permanently installed in vehicles. By 1998 more than sixty-three million Americans were using some type of cellular phone service. With the rise of cellular use, however, society was confronted with a host of new problems resulting from noisy phones and beepers going off everywhere from churches to classrooms, movie theaters to restaurants. Perhaps the biggest problem debated was the use of cell phones while driving. According to a study...