[tsimionescu]

Lying to an officer during the course of an investigation, particularly an interrogation, is not protected free speech. The officers and even the courts can't compel you to produce a password. But they may ask for a password to inspect your device, and if you choose to say "yes, I will enter my password" and proceed to enter a different password that presents fabricated data to the officers, I don't think it's far-fetched to say that amounts to lying in the course of an investigation, which is either obstruction or perjury or some other charge (I'm not well versed on the legal terminology).

Note that I'm not talking about a situation where they have you in custody or are about to, but haven't (yet) removed your phone for whatever reason, and you quickly take some action to clear it. I'm talking about a situation where they are questioning you, and in the course of questioning, request that you unlock your phone for them to inspect, you agree to do so, and proceed to wipe the phone or enter a dummy password for a fake account while pretending that you are complying with the request.

It is this second situation that happened in the article - the man being charged was held in custody and repeatedly asked to unlock the phone or risk having it seized; the man finally agreed to unlock it and provided a passcode to the officers, but the passcode instead wiped the phone.