iPods Banned in Schools to Stop Cheating

iPods and other digital media players have just been added to the list of potential tools used in cheating. Students used their iPods to cheat by downloading formulas and other references which could help them pass that exam onto their players.
To date, many (but not all) schools have adapted this new rule.
I wonder why kids who cheat "creatively" can't just study hard for the exam rather than think of ways to outsmart their teachers from finding their cheating tools.