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Suspects can refuse to provide phone passcodes to police, court rules::Phone-unlocking case law is “total mess,” may be ripe for Supreme Court review.
What if you have face unlock?
Last I heard biometrics were not protected. As in you have to unlock your phone upon request. A code, pattern or other thing you know was treated differently from using your body to unlock your phone.
No one has ever accused criminals of being smart
Criminals are just the smallest group that interact with cops and get harassed by them.