Misconfigured WAF - see my comment elsewhere here.
Correction: according to the complaint, the defendant is alleged to have assumed an IAM role in the context of Capital One's account whose policy provided access to the S3 bucket in question. So it wasn't that the S3 bucket was public, but rather, that there was some vulnerability she took advantage of by which she obtained indirect credentials to it.
(Complaint, page 6, lines 14-27.)