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So in this case:

  Whoever knowingly ... destroys ... any record ... or tangible object 
  with the intent to impede, obstruct, or influence 
  the investigation or proper administration of any matter ... or any case 
  or in relation to or contemplation of any such matter or case, 
  filed under title 11, 
  shall be fined under this title, imprisoned not more than 20 years, or both.
Wiping your phone at the border while relevant authority is searching for information under proper administration would constitute a violation.

OTOH, he did not wipe the phone himself, nor did he declare that entering a passcode would not wipe the phone but led the administration to wipe the phone. That is like setting up a booby trap that when a file drawer is opened, it would burn up, and the only way to open it would be through a side door.



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