I think it could. While a small jammer near a cell tower might not be able to overpower the transmit signal of the cell tower, even if the jammer is only a few watts it could easily overpower the receive signal. Your cell phone is transmitting even fewer watts, and is much further away from the antenna. The signal from the cell phone falls off exponentially with distance, as it radiates out ominidirectionally. So the jammer wins by power and proximity to the receiving antenna.
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