I think the article is not correct. iOS doesn't let you run an update that reboots the phone unless you input the password first (ostensibly to prevent you from being locked out on reboot).
I think Apple can force load a new OS without this limitation, but it needs physical access to do so.
Exactly correct, the article is wrong on the fundamental premise that Apple can force an over the air update. They, or anyone, can force a firmware update when connected to a wire. The Government want's Apple to create firmware that would turn off the security option in iOS that wipes the phone after 10 failed passcode attempts.
Kill Ugly Processor Architectures - Karl Lehenbauer