While it might be true that 23andMe complies with court orders in specific cases, there is likely a distinction between individual subpoenas and carte blanche catalog access for law enforcement. I say this because a famous cold case in Philadelphia was recently solved with genetic geneaology and the researcher notes explicitly that law enforcement uses GEDMatch and not Ancestry or 23andMe for these cases [0]

[0] https://www.inquirer.com/news/philadelphia/joseph-zarelli-bo...