In a Wednesday, Dec. 14, 2011 file photo, Dan Johnson uses a hands-free device to talk on a cellphone while driving, in San Diego. The National Transportation Safety Board declared Tuesday, Dec. 13, that texting, emailing or chatting while driving is simply too dangerous to be allowed anywhere in the United States. But if lawmakers follow the advice of the federal board, police officers could be faced with decoding whether someone is using their cell phone or simply singing along to the radio, pleading with backseat children to stop fighting or reciting an important sales pitch. (AP Photo/Gregory Bull, File)

(AP) -- A driver in the next lane is moving his lips. Is he on a hands-free cell phone or just talking to himself? If lawmakers follow the advice of a federal board, police officers will have to start figuring that out.

The said this week that drivers should be barred from using all cellphones - hand-held or hands-free. Such a law would be more restrictive than anything now on the books, and many police wonder how they could enforce it.

Capt. Donald Melanson of the West Hartford, Conn., police says it would be tough to determine if someone was on a phone or exercising their .

An expert says a total ban would be too draconian, but a says it probably would be constitutional.