Are iPhones the new burner phone?

As Apple and the FBI get set for their court date in a couple of weeks, this item from Reuters:

Court filings in a New York case involving the phone maker and the FBI — not the case out in San Bernardino — show that criminals are getting rid of burner phones and switching to iPhones because of the encryption.

Wiretaps of conversations show criminals calling Apple’s encryption “another gift from God.”