First, Chen must be considered a professional journalist, and securing journalist protections for bloggers seems to be actively pursued by the EFF (a conflict of interest to keep in mind).
Second, he must not have directly committed a crime himself, and receiving stolen goods is a crime. The claim that this was "lost" property may be the argument of the defense, but any case based on this seizure will surely claim that the phone was stolen. The evidence will be searched to determine Chen's knowledge of the phone's procurement.