Edit- the title of this article is possibly misleading, it appears to be the iCloud password (not phone passcode) that was reset, which rules out the possibility of getting the phone to automatically back itself up while locked in a known wifi network.
This footnote says that the owner of the phone reset the password remotely after the attack. The USA Today article says who reset the password is not clears. What accounts for this contradiction?
>>>The case has far-reaching implications for the privacy of millions of iPhone users, the Apple executive said. If the FBI is successful in its request, it will open a floodgate of requests from prosecutors nationwide.
District attorneys have lined up with hundreds of requests to unlock iPhones to solve criminal cases, the executive said. The idea that the case involves just one iPhone has been debunked, the exec said.<<<
Edit- the title of this article is possibly misleading, it appears to be the iCloud password (not phone passcode) that was reset, which rules out the possibility of getting the phone to automatically back itself up while locked in a known wifi network.