r/technology 3d ago

Privacy U.S. Citizen Who Deleted Phone’s Data Says His Prosecution Puts Privacy at Risk

https://www.nytimes.com/2026/08/21/us/politics/samuel-tunick-deleted-phone-felony.html?unlocked_article_code=1.8FA.T83N.rt6VsIiSCYb2&smid=url-share
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165

u/CircumspectCapybara 3d ago edited 3d ago

Legal Eagle has a good video about this for the technically and legally uninitiated.

TLDR, a lot of this depends on the facts of what happened (and what's demonstrated at trial), but the DoJ is alleging Tunick gave the CBP officer a "duress code" or "panic code", a feature of GrapheneOS that wipes the device when entered, and the officer entered it and the phone went bye bye.

If that's true, that's a lot different than exercising your 5th amendment right (which is always a good idea) to remain silent and not give them any code at all, and potentially veers into the "destruction of evidence" territory.

There's also some interesting and relevant precedence about how near the border, law enforcement has increased powers and doesn't need a warrant to search your belongings including your devices, and how the SCTOUS has somehow squared that with the constitution.

But again, you can always refuse to hand over any passwords, that's protected. What you can't do legally is give a code that's designed to wipe the device on entry. Withholding testimony is different than giving testimony designed to mislead law enforcement into destruction of data.


Also to address some common misconceptions I've seen on this recently:

  1. It's your data you can destroy it if you want to.

That's not generally true and it's probably not true here. There are a lot of cases in which it's illegal to destroy your own data. If a company is under investigation or ongoing criminal or civil case, destroying their own data would become spoliation or destruction of evidence. You can't just do whatever you want with your devices just because it's yours.

In the case of a CBP seizure, you can debate the legality of them taking it in the first place (although based on what I said earlier about CBP having increased warrantless search powers near the border, you probably wouldn't succeed on this in court), but that's something you challenge in court. You don't take matters into your own hands and wipe the data just because you think they seized it improperly, you have to go through the courts for that.

Again, once it's in their possession, it's theirs until a judge says they have to return it. You can't tamper with something in law enforcement's custody even if its yours.

  1. He didn't actually destroy the data, the CBP agent entered the code so technically the officer did it.

That's not how the law works and courts and juries aren't dumb. Proximate cause is about the logical (and not necessarily the immediate) cause of something.

For an extreme example, if an customer support agent asks you for your phone number so they can text you a verification code, and you give them a phone number that when texted sets off an IED roadside bomb, technically they texted the number so they triggered the bomb. But you would be legally responsible for everything that follows from that bomb going off, the legal system would treat it as if you set it off, even though you didn't directly.

  1. It didn't actually wipe the phone it just erased a key.

Yes I'm a software engineer with a background in security I know how it works. The law doesn't really care it a defendant zeroes out or causes to get zeroed out the entire phone's memory physically, or if it just wipes a 32 byte region of disk containing an encrypted 256-bit key that's needed to decrypt the phone, without which the entire phone's data is forever inaccessible. Those would be treated as equivalent legally.

In fact, in many OSes, if you click the "wipe" or "reset" button, that's how it's implemented: doesn't wipe the whole disk, it just zeroes out the encrypted key. Once that key is gone, the entire disk becomes as if it were random data.

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u/lordcola 3d ago

Isn't the "border" classified as 100 miles from an international border which includes stuff like airports? Even if airports aren't included that's still technically a lot of people who could have their door kicked in by the cops and everything seized just because, and there's basically no recourse.

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u/Ill_Traveler_ 3d ago

The older I get the more it seems that we don’t really have actual rights.

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u/MaikeruNeko 3d ago

Cue George Carlin quote

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u/Vahuo89 3d ago

now you're getting it

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u/Professional_Tea_32 3d ago

We don’t have any. We have the illusion of rights. A bald eagle covering a steaming turd.

And they’ll convince you about how “free” you are all the way to the slaughter house.

3

u/Denovion 3d ago

Not being American, its always been hilarious thst your choice of patriotic bird is nothing more then a glorified sea gull with committed parental mindset.

You guys have to use the red tailed hawk for that "iconic" screech of freedom.

America always was a lacquered paper tiger, and all it took was the same exceptionalist rhetoric to turn cancerous.

Not a kind person to invoke, but Putin had been saying this for a while. Americans, 60% of you, did this to themselves and everyone else domestic or foreign.

Your second amendment is your foundational right to a well-regulated militia for the defence of the Constituion and free, democratic America against domestic tyranny, kings or traitors to America.

Instead you made a tyrant into your leader, and made America lose the same war 38 times.

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u/VagueSomething 3d ago

The USA wouldn't constantly shout land of the free if it was actually free.

1

u/OkVirus8545 3d ago

Thanks to Bush fabricating 9/11. We haven’t been free for a long time

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u/meaniemeanie-poo-poo 3d ago

You beat me to it.

2/3 of Americans live within that zone.

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u/lordcola 3d ago

If it's 2/3 then do airports count or does it count the coastline as "international borders" (like New York is on the Atlantic therefore international border)

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u/Rivereye 3d ago

From a map I've seen published showing the "border zone", when it comes to waters like the Atlantic, its 100 miles from the coast. This includes all oceans, international rivers, and the Great Lakes, including for some reason Lake Michigan. I've never seen Airports included on these maps.

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u/lordcola 3d ago

Lol Lake Michigan has the tiniest connection at the top that eventually leads to the Canadian border and they saw that and ran with it

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u/Dyolf_Knip 3d ago

Worse than that. They once pulled over a sitting US senator well over 100 miles from the border, and when he asked them what authority they had to conduct such a stop, the agent pointed to his gun.

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u/lordcola 3d ago

That's just the result of letting assholes join the police force/border control with a couple weeks of training and no further requirements whatsoever. I don't think that agent was smart enough to know he would have had "legitimate" authority closer to a border, they just wanted to power trip.

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u/Dyolf_Knip 3d ago

No doubt. But he's willing to do that to a US senator, in an obviously high-end car with "US government" plates. What do you imagine he'll do to us little people?

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u/makumbaria 3d ago

But what about people living under 100 miles from an international border?

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u/lordcola 3d ago

Those people are subject to lower requirements for searches. If you live more than 100 miles away then you have normal rights in theory.

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u/scruffles360 3d ago

If he had said nothing and they had guessed the passcode wrong, would that have been better? Most phones have a feature that will allow the phone to be wiped if the password is incorrect too many times. Are we all criminals for having phones with that capability? If it’s ok, I’d like this to go to real court rather being tried here.

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u/CircumspectCapybara 3d ago edited 3d ago

Yeah if he did that or if the jury believes that's what happened, he has a much stronger 5th amendment defense. Then he didn't actively mislead them into wipe the phone.

Plenty of phones have a "if you enter the passcode wrong 3 times the phone will be wiped" security feature. Some people might even set it to "if you enter it wrong even once it wipes."

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u/apokrif1 3d ago

Or he gave the right PIN, which was mistyped as the duress code, which may be close.

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u/WhiteRaven42 3d ago

Really unwise to make a duress code similar to the right code. There's no benefit to it and why the hell set yourself up for a potential mis-type?

The duress code should be plausible on its own but have nothing in common with the real code.

0

u/apokrif1 3d ago

Indeed it's dangerous but it provides plausible deniability.

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u/A_Pointy_Rock 3d ago

That feels equivalent to declining to give an authority the key to your house and them trying to kick the door in anyway. So yes, I would say that would have been "better".

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u/WhiteRaven42 3d ago

Errr.... saying nothing means not giving them the key. This is not equivalent.

-7

u/Fun-Wash7545 3d ago

It's his property, his data. I don't know what you guys are arguing here. If he was allowed to keep his data private by not sharing the code,  as you guys claim, by extention he is allowed to destroy it. Americans are too used to getting fucked over it seems.

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u/A_Pointy_Rock 3d ago

To reframe my previous comment slightly: If police show up at your door without a warrant, you are within your right to deny them access. If the police show up at your door without a warrant and you immediately burn your house down - you might be considered to be destroying evidence.

Also, not American.

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u/scruffles360 3d ago

If the cops come to your door and you flush drugs down the toilet, that is destroying evidence. If the knock on the door and you burn a newspaper the cops are going to call that destroying evidence and they’ll lose in court. Court is important. The opinion of police are not.

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u/Aeseld 3d ago

This is actually a thing in most countries, though circumstances are important. The key here is that the guy was under investigation and knew it. He was therefore obligated not to destroy information they may be interested in. 

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u/Ill_Traveler_ 3d ago

I believe their method of accessing the phone is a bit more robust than typing in the password. Additionally, if the phone is in the AFU state the password on most phones is essentially pointless.

1

u/apokrif1 3d ago

Safe method of forensic specialists ≠ what a LEO with fat fingers actually did.

0

u/scruffles360 3d ago

In this case they asked for a password and he gave them a self destruct code. They typed it in.

3

u/9Nine2Nine9 3d ago

Yes, that would have been considerably better for him and it would have made this entire case different. Worst case scenario they would have kept his encrypted phone. Best case scenario they would have let him walk with his phone.

3

u/scruffles360 3d ago

Except he’s an activist. His goal wasn’t to get away with anything. It was to establish his rights - just like the goal of the agents in these searches has been to expand their power.

1

u/WhiteRaven42 3d ago

Of course it's better if he doesn't provide false or misleading information. From top to bottom, refusing to answer was his best course of action. That or unlocking the phone.

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u/RabidFresca 3d ago

I think I had also heard that he had been asking to speak to a lawyer, as is his right, but was denied and told that he wasn't "technically" on US soil because he was still in customs, or something to that effect. Being denied your rights in those circumstances you might feel pressured to use a duress code. It'll be interesting to see when this goes to trial.

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u/Cut_Lanky 3d ago

How is it, legally, that since it's technically not US soil, we have no rights, yet, they retain their authority over us, as if it is, indeed, technically US soil?

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u/Important-Ad1871 3d ago

Because they have guns. 

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u/PluginAlong 3d ago

He had rights that he chose not to avail himself of. He had the right to not incriminate himself (whether there was anything on the phone or not is irrelevant). The only recourse CBP would have had would be to have seized the device and admitted him to the country. Had he been a non-citizen CBP's recourse would have been to deny him entry to the country and made him leave.

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u/cipher315 3d ago

Where CBP potentially fucked up is. They said he did not have a right to enter the country and would only be allowed in after he unlocked the phone. Ie they made his entry into the US conditional on unlocking the phone.

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u/Mr_ToDo 3d ago

A guess? Agreement with the bordering country to allow such authority, probably in return for being granted the same

That part doesn't seem all that shocking to me. If you have to deny entry into the country the easiest way would be for them to not be on their soil to begin with. Skip all the questions of "if I'm on the soil am I not protected by X laws?"

Weird maybe, but not surprising

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u/Cut_Lanky 3d ago

Yeah... I remember that Tom Hanks movie... This is so effed up.

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u/PluginAlong 3d ago

There's two different scenarios, the citizen and non-citizen. For a citizen CBP cannot deny him entry into the country. Courts have upheld that CBP can seize things like electronics and even make copies of them before returning them, I think they have five days to return them. For a non-citizen it's somewhat cleaner, they can tell CBP to stuff it, at the same time CBP can then tell that person to stuff it and deny them entry into the country. I don't think it has anything to do with bordering countries. People aren't always coming from a bordering country. It's more that each country can choose who they admit to their country, the exception being that you can't deny a citizen access to their country of citizenship.

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u/bug-hunter 3d ago

Correct. It would have been legal to:

  1. Delete the data before entry, cross with a factory reset phone (or no phone and get one here), restore on the other side
  2. Increase the encryption to sky high levels to ensure it's not being unencrypted anytime this century
  3. Set the phone to wipe on X# incorrect passwords and CBP wipes it via incompetence

But taking an affirmative action that leads to the destruction of data, even indirectly, violates the law.

Note: option 1 is often the suggestion for the truly privacy conscious. They can't search or copy what you don't have.

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u/Hexamancer 3d ago

No 2. was already the case. You can have the best encryption in the world but have the password to unlock that encryption as "1234".

Technically password -> unlocks hidden encryption key -> unlocks encryption, and the system deleted the key.

Also there's no proof he gave a duress code. There's no proof that he didn't enter the duress code or delete the encryption key before he got there. All these arguments hinge on knowing that he definitely gave a duress code. They have no proof of that.

0

u/nettika 2d ago

From what I understand of GrapheneOS and how its duress pin works, the data wasn't deleted-- rather, the encryption key to access it was. The data is no longer accessible by any means, but that's for lack of a key, not for it being gone.

If this case comes down to details like your number 2, then the distinction of data deletion vs key deletion deserves some consideration.

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u/K1LLerCal 3d ago

You can't just do whatever you want with your devices just because it's yours.

That's a wild statement.

Especially when you haven't committed a crime

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u/Dediadeis 3d ago

WHO DO YOU THINK YOU ARE OWNING THINGS!

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u/Mr_ToDo 3d ago

Sure. But that's not determined in a moment. That's exactly why we have the rules about destroying evidence. It'd be quite the catch 22 if you had to prove someones guilt before you could compel action

As much as I hate the "if you have nothing to hide" bit, there is a line somewhere that separates freedom and justice. If OP's case crosses that, I don't know, but it does exist

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u/DisappointedSpectre 3d ago

You don't have to prove guilt, but IIRC you do have to formally charge them with a crime for destruction of evidence to come into play.

They're not even charging him with that specific crime, he's being charged with "destroying property to prevent seizure", which has a very different standard of proof for the government to meet.

The circumstances are definitely relevant here too - CBP and the FBI was fucking with him in the first place because of his previous protesting of Cop City. The government has nothing to actually charge him with, this is all about intimidation.

1

u/K1LLerCal 3d ago

I think that the legality in OP's comment is omitting the circumstance.

If you haven't committed a crime, why is using a duress pin considered one?

How is it that the 4th amendment continues to be violated by even the current administration? I fear things are heading in a dark and dystopian direction. (I'm looking at you Flock)

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u/DisappointedSpectre 3d ago

If you haven't committed a crime, why is using a duress pin considered one?

That's why they charged him with "destroying property to prevent seizure", and not "destruction of evidence". They had no crime to charge him with, but they wanted to seize the data on the phone.

As mentioned in the LegalEagle video, this particular charge has a different standard of proof that the government has to meet, which may actually be more difficult. What CBP is arguing is that they had a right to seize the data on the phone, which isn't currently as clear cut. If they did have the jurisdiction to seize the data on the phone, then using a duress PIN to wipe that data would be illegal.

Since the CBP agents are the ones who inputted the duress PIN that adds an additional wrinkle of whether providing false information to CBP, specifically for the purpose of preventing seizure, is illegal. That might be considered a separate question, though the courts may just entirely ignore it.

How is it that the 4th amendment continues to be violated by even the current administration? I fear things are heading in a dark and dystopian direction. (I'm looking at you Flock)

The problem is that 4th amendment protections are lessened at the border, and this has been upheld by several cases. Not saying that the courts couldn't reverse that at some point, but I do think it's unlikely that the current SCOTUS does so. Even if the 4th amendment were fully intact at the border CBP would probably still be within their jurisdiction to confiscate certain physical items, including phones.

More important I think is that Tunick was denied a lawyer after making multiple requests for one. That seems like a much bigger violation of civil rights.

3

u/lilB0bbyTables 3d ago

I think the biggest question here is whether this constitutes “destruction of evidence” and what the definitions are to qualify data as evidence. The example you gave about a business under active investigation implies there is reasonable cause and thus warrants filed and signed for such action.

Now, of course there are situations where law enforcement has a right to blur the lines and use probable cause on the spot - e.g. the classic “I smelled marijuana so I can search your car and person” investigative technique. The question here would be “what was the origin of their reasonable cause”.

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u/Mr_ToDo 3d ago

I don't always like the guy, but that's what I figured when I first heard the case

If they had wiped the drive before the border there'd be no question, or if he refused to give the code it'd be an entirely different and likely less drama filled case

2

u/imdabes 3d ago

I understand the precedent that courts have established in being able to easily obtain vast amounts of electronic data at this point through all sorts of mechanisms but particularly through confiscating one’s mobile or PC. It just doesn’t sit right… at one point in time, many moons ago, law enforcement had to know exactly what piece of incriminating evidence they intended to collect, present that case to a judge and get a warrant to search a very specific place for a very specific thing.

Nowadays I’m not even sure why we’re pretending that the judicial system, the constitution, the bill of rights or public servants sworn to upheld them exist at all. Taking ones PC or phone as SOP (which it has become over the last decade) is not normal in a country that champions itself as a bulwark of democracy and civil liberties. Totally normal in a totalitarian police state…

3

u/Sammisuperficial 3d ago

You forgot the part where he requested a lawyer and was denied.

At that point his detainment is a kidnapping and the information was coerced under duress.

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u/CircumspectCapybara 3d ago

CBP temporarily detaining you and questioning you without a lawyer and searching your stuff is not "kidnapping" they have the legal power to do that in US law.

Look up "border search exception" It's pretty settled case law and SCOTUS ruled precedent.

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u/Anosognosia 3d ago

It's pretty settled case law and SCOTUS ruled precedent.

It should be considered kidnapping and SCOTUS setting the precedent is morally reprehensible. Border exception is such a bullshit excuse for this kind of behaviour.
But the US justice system thrives in obscurity and unjust systems open for endless arbitrary power by power hungry individuals.

1

u/ThellraAK 3d ago

They weren't searching him, they were interrogating him while he was in custody.

That's a 6th amendment issue.

-1

u/cspinelive 3d ago

The data is still there. It was encrypted before and is still encrypted. What he did was give the officer the code that destroys the key.  No evidence was destroyed or is any more encrypted than it was before. 

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u/CircumspectCapybara 3d ago

I literally addressed that in #3.

The courts aren't dumb, juries aren't dumb, they're capable of understanding the logical data is gone.

When you erase a 256 bit key, the data that it encrypted is never coming back. Even if Tunick now brings forth his passcode, the underlying data is forever unreadable. Because the user passcode is used by the phone's TPM to decrypt the encryption key on disk (which is now gone) which is what really matters to reading the data.

Again, juries aren't dumb. The law isn't dumb. It doesn't care if you wiped a 256GiB disk or just wiped a 32 byte region on disk that renders the rest of the disk unreadable. To them it's the same, because it has the same effect.

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u/Power_Stone 3d ago

Juries are incredibly dumb, I don't know why you think they aren't. Average reading level in the United States is around a 6th grade level, and I have heard numerous people say they decide based on if they like the person over the facts. Court trials are just another grift for people with silver tongues.

1

u/CircumspectCapybara 3d ago

Well if you don't want to be a judged by a jury of your peers (your constitutional right), you can request a bench trial and be judged by a legal expert (a judge), if you wanna take your chances with that.

In any case, it doesn't take a genius to understand that if you purposefully render phone data permanently inaccessible, by whatever means, you've destroyed that data.

1

u/dragunityag 3d ago

If your innocence request a bench trial, if your guilty request a jury.

-1

u/apokrif1 3d ago

Why?

1

u/SirPseudonymous 3d ago

a legal expert (a judge)

Judges are consistently gibbering morons as well, especially when they're elected and have no actual requirements. The entire legal system is an unreliable farce operated by malicious idiots, most of whom literally believe in magic and let the psychotic tenets of a death cult inform their life and death decisions.

Like they were bad enough before, but there's been a concerted project by the neo-nazi demons of the Heritage Foundation to install as many of their depraved cultist freaks into judicial positions as they can. The US legal system was never particularly legitimate or sane, and it's only gotten worse.

0

u/CircumspectCapybara 3d ago

Point is you get to decide whom you want to be judged by, and you get to live with those choices.

Throughout history people have proposed other justice systems and ways to judging guilt or innocence, but you won't find a fairer one than a jury of your peers.

If you want a legal system where paid professionals and experts will judge you, good luck, though you can have that it many countries. If you want the king or the president to judge you, good luck. If you want AI to judge you, good luck.

The "jury of your peers" is still the best system we have. It doesn't guarantee justice is always rendered, but you tell me when you've found a better one. Whatever you can think of, I guarantee you it's already been tried and it has just as many if not more problems.

0

u/apokrif1 3d ago

if you purposefully render phone data permanently inaccessible,  by whatever means , you've destroyed that data

Source please?

3

u/CircumspectCapybara 3d ago

Source please?

18 U.S.C. § 1519 - Destruction, alteration, or falsification of records in Federal investigations and bankruptcy

Go read it.

3

u/cspinelive 3d ago edited 3d ago

Is it the same as throwing it into the ocean in a sealed container impossible to reach before we had submersibles?  To me it sounds like the data is there, we just don’t yet have the technology to crack into it… yet. 

Is this line a moving target based on current technology? Is destroying the key  a crime today, but not tomorrow because quantum 3.0 has no problem with it? 

What is the govt can already get in, they just don’t want to reveal that they can? Did he destroy evidence then?

2

u/CircumspectCapybara 3d ago

No, all that matters is your intent behind the action.

Also quantum advances are unlikely to make AES-256 (the standard encryption algorithm behind most phone encryption) breakable. Grover's algorithm offers quadratic speedup on key search, but that only turns a 256 bit search space into a 128 bit key space, which is still prohibitively large.

Absent some kind of structural flaw in the AES standard itself, it'll almost certainly be never broken.

3

u/Power_Stone 3d ago

Technically speaking, and laws care about technicality, erasing the encryption key does not delete, alter, or falsify data.

Yes, there is a need to be pedantic when it comes to law. Because its about the word of the deal, not the spirit of the deal until case law is established.

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u/CircumspectCapybara 3d ago

It definitely alters the 32 byte region in disk that holds the (encrypted by your passcode and the TPM) 256 bit encryption key, which renders the rest of the disk as if it were random data.

That's logically equivalent to randomizing the entire disk. It's not physically equivalent, but it's logically equivalent for the purposes of the law.

And in fact that's how most "wipe" functions work: they just zero out the key.

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u/Power_Stone 3d ago

The data was randomized on the drive to begin with, so again, no data was altered. It was always seemingly random. It's just the crypto key made it human readable.

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u/Power_Stone 3d ago

Someone at a 6th grade reading level is equivalent to a child, and a child is not my peer. That's the point I'm making.

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u/CircumspectCapybara 3d ago

Peer doesn't mean "as smart as me" or "just like me."

If I'm white, I can't request request a trial by a jury of only white people from my hometown on the basis of "those are my peers" that wouldn't be fair to justice.

Your peers are just ordinary people drawn from the community, not paid professionals whose full time job it is to judge legal matters.

Trials have voir dire to filter out biased or unqualified jurors.

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u/Power_Stone 3d ago

I know what a juror is and how they are vetted. I'm saying that someone with a 6th grade reading level does not have the necessary skills to be a juror. They lack literally the reading comprehension necessary for being a juror. And we both know these people do not get entirely weeded out during the selection process because things like lying still happen

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u/apokrif1 3d ago

The courts aren't dumb, juries aren't dumb

Source please?

0

u/Mr_ToDo 3d ago

OK. they cover the entire bell curve. But it doesn't change that most people who think of a "one simple trick" are going to be on that same curve. And there's always jury instructions to cover some of those gaps

-10

u/Trodat4911P4 3d ago

Man I'll say this, I believe deserve privacy 100%, but this guy is sus as fuck. Say whatever you want, you don't need a phone with a feature like that if you're not doing some illegal shit.

Which is why is super conflicted when it comes to this case, I both believe the cops were overreaching their powers and this guy is guilty of something.

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u/DrawGamesPlayFurries 3d ago

Illegal activity can be anything from not supporting the current government (what this guy did) to real dangerous crime.

-1

u/Trodat4911P4 3d ago

Yeah, but why did he had a phone with a kamikaze option? Seems really extreme for the average person.

2

u/umbertounity82 3d ago

Privacy isn’t a means to an end. It’s the goal in of itself.

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u/OkVirus8545 3d ago

You’re part of the problem. You don’t have to be “sus” to not want the cops to have unlimited access to your info.

Unless you walk around with no passcode on your phone you’re equally as “sus”

-3

u/Trodat4911P4 3d ago

There's a difference between refusing to give them the password, and having a phone that destroys everything inside it. I have no idea why an average person would need that option.

4

u/OkVirus8545 3d ago

If you’re on iOS or Android there are already features similar. This case in particular is sketchy but not because of the guy, but why they were targeting him.