> The only way there should be a legal hold on a phone like that, is if it is her work phone, which she shouldn't be having nude pics of herself on in the first place.

some people use their personal phone for work email, etc. and miss the fact that that makes the phone basically a company property - i.e. the company can wipe it remotely, etc.

Wrt. Apple requiring to not wipe out laptop before returning it i wonder how do they enforce it. In more than 2 decades i have never returned laptop without wiping it and wonder what can change that, if any.