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You can say it was a wiped phone to begin with, and that may work in court. They're welcome to have evidence it wasn't true, but whether they actually have that evidence is up in question.

But it's irrelevant in this case because the guy confessed.



When you enter the unlock code to a phone that was already reset, it immediately unlocks.

When you enter the duress code, you get an animation while it resets, and then it reboots to a factory reset state.

It is directly observable which code was entered. You can claim that it was something else, but your claim is easily dismissed as bullshit.

This was exactly what was observed and recorded by the officials in this case.




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