Sure, but Stoddard had no right to enter RH's phone without a search warrant, and yet, he was asking for the password. Twice.
June 2014 Supreme Court Ruling
"The fact that technology now allows an individual to carry such information in his hand does not make the information any less worthy of the protection for which the Founders fought," the ruling said. "Our answer to the question of what police must do before searching a cell phone seized incident to an arrest is accordingly simple — get a warrant."
Quote from CNN: "The Supreme Court on Wednesday unanimously ruled that police may not search the cell phones of criminal suspects upon arrest without a warrant -- a sweeping endorsement for privacy rights.
"By a 9-0 vote, the justices said smart phones and other electronic devices were not in the same category as wallets, briefcases, and vehicles -- all currently subject to limited initial examination by law enforcement."
[video=cnn;crime/2014/06/25/tsr-toobin-cell-phone-supreme-court-ruling.cnn]http://www.cnn.com/2014/06/25/justice/supreme-court-cell-phones/index.html[/video]
It's not as simple as that, apparently, especially since there is the matter of the legality of the LE's initial seizure of his phone at the scene. Wheee is THAT a complicated issue, but crucial of course, because they couldn't search it without a search warrant if they didn't already have it their possession..
Two warrants are required - one for the phone itself, a second to search the contents of the phone.
LE already had the phone. The SW they obtained the same night for the phone, 3 hours after RH's interview with Stoddard ended, was for the phone itself, not for searches on the phone.
But...Staley ruled that RH gave implied consent for LE to search those contents when he agreed to give LE his passcode. I don't believe any Georgian appellate court is going to disagree with her interpretation of the applicable laws.