However, it makes an erroneous equivocation that, I believe, has profound technical and legal implications. In the article's first paragraph, it claims that GrapheneOS "enables users to enter a passcode and wipe a phone clean". What the author of the article is referring to is GrapheneOS's duress password/PIN feature[1], which does not (contrary to what it may seem on first glance) delete or modify the data on the persistent flash storage phone in any way. What it does is zero the key slots in the phone's Secure Element, which stores the disk encryption keys necessary to decrypt the data on persistent storage (technically, these disk encryption keys are not themselves stored in the secure element, but are first encrypted with a key encryption key/KEK derived from a user-entered passcode/PIN and then stored in the secure element[2]. If an adversary were able to break the secure element and extract the contents of the key slots, they would still need to brute-force the KEK in order to obtain the actual disk encryption keys).

To my knowledge, US law does not explicitly say whether deleting the key necessary to decrypt a given ciphertext is equivalent to deleting the ciphertext itself. Technically speaking, they are not equivalent, even if it would take an exorbitant amount of time to recover a deleted key using a brute-force search or some forensic method. If the federal government wants to claim, using this case to set a legal precedent, that it is equivalent, then I would argue that this in effect makes encryption as a concept illegal (as encryption is nothing without the ability of the person using encryption to control access to the encryption key(s)). Reading about the recent Prairieland trial, in which (among other blatant injustices) an activist was convicted by a kangaroo court of "destroying evidence" because they merely removed someone from a Signal group[3], it's clear to me that Prairieland along with Sam's case is part of a coordinated strategy under the NSPM-7 "Antifa Memorandum"[4]: the federal government is using lawfare to establish that it has a right to arbitrarily access the data of its citizens in order to crush political dissent.

[1] https://grapheneos.org/features#duress

[2] https://grapheneos.org/faq#encryption

[3] https://www.theguardian.com/us-news/ng-interactive/2026/jun/...

[4] https://en.wikipedia.org/wiki/NSPM-7