Maybe it's slightly more nuanced than I thought. This (https://crsreports.congress.gov/product/pdf/LSB/LSB10416) seems to be an interesting report on the issue, although in most cases a defendant cannot be compelled to unlock their password-protected device. Biometrics might be different, but honestly, don't use a fucking fingerprint unlock if you've got "sensitive shit" on your device. Duh...
Multiple people have been held in contempt for refusing to provide an encryption password by US courts.