Thanks for your response. "A specific user's behavior must be observed for intent to be accurately deduced." Excellent point. Overall I think you've convinced

Thanks for your response. "A specific user's behavior must be observed for intent to be accurately deduced." Excellent point. Overall I think you've convinced me, in the general case, not only that a person should not be required to unlock his or her own phone, but that law enforcement (e.g., FBI) should not be permitted to attempt to access the phone. A possible exception in my mind would be accessing the phone to get information generally acknowledged to be objective and straightforward -- such as location data. But then it perhaps becomes a Fourth Amendment issue. It seems to me that in the (entirely hypothetical and unlikely) case that such data were not accessible via warrant from the cell phone provider that a limited warrant (for position data only) could be enforced, assuming probable cause were established. https://www.supremecourt.gov/opinions/17pdf/16-402_h315.pdf https://www.supremecourt.gov/opinions/17pdf/16-402_h315.pdf