If Apple is compelled to create a program that doesn’t exist for the government, that would be a type of slavery.

From Reason.com:

Instead, the DOJ has obtained the most unique search warrant I have ever seen in 40 years of examining them. Here, the DOJ has persuaded a judge to issue a search warrant for A THING THAT DOES NOT EXIST, by forcing Apple to create a key that the FBI is incapable of creating.

There is no authority for the government to compel a nonparty to its case to do its work, against the nonparty’s will, and against profound constitutional values. Essentially, the DOJ wants Apple to hack into its own computer product, thereby telling anyone who can access the key how to do the same.

If the courts conscripted Apple to work for the government and thereby destroy or diminish its own product, the decision would constitute a form of slavery, which is prohibited by our values and by the Thirteenth Amendment.