Apple has told reporters off the record that the FBI could make the same demands for Secure Enclave equipped iPhones, probably because the Secure Enclave can be

Apple has told reporters off the record that the FBI could make the same demands for Secure Enclave equipped iPhones, probably because the Secure Enclave can be updated. That's why they're making their stand in this case. In the future Apple may make it so that the iPhone must be unlocked before an update could be applied, but that isn't the case now.