I would assume that even if the software/cryptography is secure, Apple would have a physical/hardware-based way to access the data. But they can't admit to this as its a big part of their marketing around the product.
I think there may be an Israel-based security company that has managed a hardware bypass. But this was a few iPhone generations ago. Not sure about the latest products.
All the existing attacks have started with at least a partially unlocked phone.
But can you discount a scenario where a hardware hookup and brute forces through all possible numeric security codes? Could take less than a minute. Who is to say there isn't a bypass that allows them to do this? Very hard to tell
I am aware of two bugs in that logic over the years - I can’t find the articles off the top of my head. One was essentially a TOCTOU bug that could be triggered via voltage spikes to reset the device after you tried to unlock but before it updated the retry count. The other required imaging and restoring the flash between each attempt. I don’t know how that was fixed, but it should hopefully be obvious that That is going to take more than a minute to brute force a 6 digit passcode.
As in the investigation into the Pensacola shooting, the San Bernardino gunman, Syed Rizwan Farook, was also dead and no longer had a right to privacy.
In this case, Barr has a better chance of Apple complying, by simply routing the request through China.