I recall a supreme court decision that law enforcement cannot force someone to offer their password, as it is a violation of the 5th ammendment: https://techcrunch.com/2019/11/21/court-police-suspects-pass...

However, in this most recent case, it was not a password used to unlock the phone but facial recognition:

> The judge granted the Justice Department's request to place Capitol riot defendant Guy Reffitt in front of his laptop so they could use facial recognition to unlock the device

And apparently this is not protected by the same ruling, which is interesting.