The Fifth Amendment provides an individual protection against being “compelled in any criminal case to be a witness against himself.” Passwords, which are an expression of the contents of an individual’s mind, fall squarely within the protections of the Fifth Amendment. For devices that are unlocked via fingerprint, the Eighth Circuit has found fingerprints to be non-testimonial evidence, but producing a fingerprint can communicate possession or control of the device as testimonial evidence. Nevertheless, even if a fingerprint is obtained to unlock a phone, a password is still needed to download the contents of the phone.