The movement done by someone driving a car, leaning the head and upper body far to the right and down while talking, illegally, on his cell phone in the mistaken hope that no one can see him.
This movement can be difficult, causing the driver to operate the vehicle much slower than the posted speed limit and to weave out of his lane.
Can be confused with the "gansta lean," which goes to the left and is legal.
"Pass this guy at the next light, he's doing the cell phone lean."
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