Requiring a person to unlock a device is not prohibited by the Fifth Amendment simply because the device contains incriminating information that would otherwise be inaccessible to police.

If the police have a valid warrant to search your safe, you are generally required to unlock it for them, even if the safe contains evidence that incriminates you. If you are issued a valid subpoena to produce certain documents in your possession, you are generally required to produce those documents, even if they incriminate you. Compelled decryption of hard drives is fundamentally no different.

It is true that the act of unlocking the safe or producing those documents is itself testimonial in the sense that you are conveying the fact that you know the combination or possess those documents. But under the "foregone conclusion" doctrine, if the state already knows that implicit testimony, then it is not protected by the Fifth Amendment. It's obvious that Rawls knows the password to the drives.

There are legitimate concerns about how search warrants should apply to electronic devices. However, these are Fourth Amendment issues, not Fifth Amendment ones.

If you're interested, Orin Kerr from the Volokh Conspiracy has written several articles about compelled decryption, including with respect to this particular case [1, 2, 3].

1: https://www.washingtonpost.com/news/volokh-conspiracy/wp/201...

2: https://www.washingtonpost.com/news/volokh-conspiracy/wp/201...

3: https://www.washingtonpost.com/news/volokh-conspiracy/wp/201...