404Media is reporting that the FBI could not access a reporter’s iPhone because it had Lockdown Mode enabled:

The court record shows what devices and data the FBI was able to ultimately access, and which devices it could not, after raiding the home of the reporter, Hannah Natanson, in January as part of an investigation into leaks of classified information. It also provides rare insight into the apparent effectiveness of Lockdown Mode, or at least how effective it might be before the FBI may try other techniques to access the device.

“Because the iPhone was in Lockdown mode, CART could not extract that device,” the court record reads, referring to the FBI’s Computer Analysis Response Team, a unit focused on performing forensic analyses of seized devices. The document is written by the government, and is opposing the return of Natanson’s devices…