Forgetting the keys is established as protected speech under 1A. Don’t have the case handy atm. Fairly new. Knowing the keys and intentionally withholding them has yet to be established either way. But there will be a case soon enough. Funny thing about law is that both sides (prosec. & defense) often don’t want many things clarified further because they usually have far-reaching impacts to parallel legal issues. Roe v Wade is a perfect example.