This has been the law for a while, it's just that more Circuits are aligning. Don't use biometrics if you don't want LEO to be able to access your phone. A password is covered by 5A in some circuits and in others it's likely sufficient to just refuse or claim faulty memory due to the stress of the situation. Regardless of the location, the contents of the device are covered by 4A and you may succeed in getting a lot of whatever is found thrown out -- classic you can beat the rap, but you can't beat the ride.