A memo released Friday by the Miami-Dade County State Attorney's office concludes there is no evidence that Brown intended to steal the phone in February or that he deleted the photo. One or the other is necessary for him to be charged.
Prosecutors say that Brown tossed the phone from his limo and that it was picked up by security.
A felony charge against the 24-year-old might have triggered a violation of his probation for his 2009 assault on singer Rihanna, who was his girlfriend at the time. The two have recently collaborated on a new duet.