Last month, the Pennsylvania Supreme Court ruled that it is a violation of the Fifth Amendment’s protection against self-incrimination to compel a defendant to disclose a password to allow police access to a “lawfully seized, but encrypted, computer.”

In 2015, the attorney general’s office was conducting an investigation into the use and distribution of child pornography. The attorney general sought a search warrant for Joseph J. Davis’ home after his IP address was linked to child pornography videos and a file-sharing network. Davis admitted to watching child pornography, and law enforcement officials lawfully seized his computer. However, he refused to provide the 64-character password to his computer.