Lavabit did it to themselves. They initially subpoenaed just the account they were interested in. Lavabit claimed it was not possible to comply, so the next request was for master keys.
At this point, Lavabit could've complied by just handing over the original data, but instead decided to get cute. "Contempt of court" is an aptly named crime.
At this point, Lavabit could've complied by just handing over the original data, but instead decided to get cute. "Contempt of court" is an aptly named crime.