On their newer models, yes, there are hardware-based protections. The guy in this case didn't have the newest model iPhone; he has an older 5C which is at leas

On their newer models, yes, there are hardware-based protections. The guy in this case didn't have the newest model iPhone; he has an older 5C which is at least theoretically vulnerable to Apple being forced to push a bad software update to it. It's hard not to see the effects of these things showing up in the way they design each successive generation of iPhones; each time, they add something which gives them more ways to say "nope, technically impossible to do what that court just ordered us to do".