But at least in this case, the phone didn't actually hit anyone.
The recent divorcee is being investigated for allegedly destroying a photographer's phone in New Orleans on March 12.
Snapper Timothy Jackson filed a police report claiming that Russ approached him on the street, grabbed his phone and hurled it through a glass window.
New Orleans police are planning to question Russ over the photographer's claims of "criminal damage".
This isn't the first time the star has had a run-in with a paparazzo. He was arrested for battery after a scuffle with a photographer at LAX airport in 2010 but the charges were later dropped.