In a must-read opinion for any criminal practitioner, in a 4 to 3 split, the New Jersey Supreme Court ruled in State v. Andrews that, pursuant to a valid search warrant, a suspect can be compelled to divulge the password to access his cell phone. The Court rejected the defendant’s arguments that his 5th Amendment right against self-incrimination forbade such a result. On the contrary, the Court held that the foregone conclusion exception to the right against self-incrimination was satisfied. 

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