In a sense, yes. One of Lavabit's failings is that they didn't design for scope-limited disclosure. When the FBI demanded their certs, it exposed all their users.
Don't overthink it. The failure of Lavabit was designing a system that enabled disclosure at all. It wasn't end-to-end encrypted; its users had to trust its operators, which, because operators can always be coerced, is never safe.
