The latest information on macrumors.com about the iPhone case mentions that the FBI request could have been avoided if the Apple ID password was not changed before. There Apple says that the device would have start automatically iCloud backup if Wifi enabled to a known SSID would have been. See the article here
Does iCloud sync run automatically even the device is locked but wifi on?
Yes it does, basically it is a background task
Extracts from an apple support document
What iCloud backs up
iCloud automatically backs up the information on your devices—iPhone, iPad, and iPod touch—over Wi-Fi every day when they are turned on, locked, and connected to a power source. When your iOS device information is backed up in iCloud, you can easily set up a new device or restore information on one you already have.
Here is the link for it https://
Thanks! Oposite question Which circumstances have to be given that iCloud CANNOT start except the obvious like No web access, not signed into iCloud?
What factors may unintentionally stop iCloud sync from running even basically enabled in settings? Search for the irrational piece suspects may miss?