State v. Andrews

In a must-read opinion for any criminal practitioner, the Supreme Court in a 4-3 split 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. To the contrary, the Court held that the forgone conclusion exception to the right against self-incrimination was satisfied.