Lavabit held an encryption key that could decrypt evidence of a crime. They received a subpoena for that key. They followed what was likely any lawyer's advice

Lavabit held an encryption key that could decrypt evidence of a crime. They received a subpoena for that key. They followed what was likely any lawyer's advice to comply with the lawful subpoena (ordered by a judge, not a TLA). This reasoning would not apply to CA's.