From my understanding in the previous cases the passcode only limited access to using the phone, not to the data inside. This is the same situation as having a

From my understanding in the previous cases the passcode only limited access to using the phone, not to the data inside. This is the same situation as having a password protected PC but not having your disks encrypted. You need to know the password to be able to use the computer, but anyone that has physical access to your machine can just take the disks and read your data using another computer. From reading the article this is how Apple has helped law enforcement previously. Now in more up to date versions of iOS the passcode limits access to using the phone, in addition to limiting access to the data contained inside. This limits what Apple can do to help law enforcement in the previous scenario, since any data they could copy off the phone would still be encrypted.