"Apple strongly supports, and will continue to support, the efforts of law enforcement in pursuing justice against terrorists and other criminals — just as it has in this case and others," Apple argued. "But the unprecedented order requested by the government finds no support in law and would violate the Constitution."
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While the government maintains its request is narrow and specific — unlocking a single phone — Apple asserts that's simply not true. As soon as news of the court's order broke last week, state and local officials publicly said they planned to use the new software to open hundreds of other seized devices.
"Once the floodgates open, they cannot be closed," Apple wrote. "And the device security that Apple has worked so tirelessly to achieve will be unwound without so much as a congressional vote."
The filing is 36 pages long and it's chock full of legal vernacular, but those who care to parse it can read below.
One of Apple's key arguments in the filing centers on what it sees as the government's interpretation of something called the All Writs Act that would compel Apple to write code to bypass its security:
If Apple can be forced to write code in this case to bypass security features and create new accessibility, what is to stop the government from demanding that Apple write code to turn on the microphone in aid of government surveillance, activate the video camera, surreptitiously record conversations, or turn on location services to track the phone's user? Nothing.
Apple argues that the venerable All Writs Act wasn't created to provide the courts "free-wheeling authority" to exercise new powers not afforded the courts by Congress — such as conscripting Apple to help the government hack iPhones. In fact, it notes, no court has ever authorized what the government is looking for, Apple maintains.