404Media is reporting that the FBI could not access a reporter’s iPhone because it had Lockdown Mode enabled:

The court record shows what devices and data the FBI was able to ultimately access, and which devices it could not, after raiding the home of the reporter, Hannah Natanson, in January as part of an investigation into leaks of classified information. It also provides rare insight into the apparent effectiveness of Lockdown Mode, or at least how effective it might be before the FBI may try other techniques to access the device.

“Because the iPhone was in Lockdown mode, CART could not extract that device,” the court record reads, referring to the FBI’s Computer Analysis Response Team, a unit focused on performing forensic analyses of seized devices. The document is written by the government, and is opposing the return of Natanson’s devices.

The FBI raided Natanson’s home as part of its investigation into government contractor Aurelio Perez-Lugones, who is charged with, among other things, retention of national defense information. The government believes Perez-Lugones was a source of Natanson’s, and provided her with various pieces of classified information. While executing a search warrant for his mobile phone, investigators reviewed Signal messages between Pere-Lugones and the reporter, the Department of Justice previously said.

Microsoft gives the FBI the ability to decrypt BitLocker in response to court orders: about twenty times per year.

It’s possible for users to store those keys on a device they own, but Microsoft also recommends BitLocker users store their keys on its servers for convenience. While that means someone can access their data if they forget their password, or if repeated failed attempts to login lock the device, it also makes them vulnerable to law enforcement subpoenas and warrants.