FYI BitLocker is on by default in Windows 11. The defaults will also upload the BitLocker key to a Microsoft Account if available. This is why the FBI can compel Microsoft to provide the keys. It's possible, perhaps even likely, that the suspect didn't even know they had an encrypted laptop. Journalists love the "Microsoft gave " framing because it makes Microsoft sound like they're handing these out because they lik…
The same is true for Apple laptops! Take a look in your Passwords app and you will see it automatically saves and syncs your laptop decryption key into the cloud. So all the state needs to get into your laptop is to get access from Apple to your iCloud account.
That said, when setting up FileVault, you have the option to escrow your recovery key with Apple. If you enable that, Apple can get the recovery key.