There seem to have been several lock screen bypass bugs over the years. Given that, you'd think they'd give it a hammering and find this stuff.
The bugs seem to a bit more nuanced than just testing for a locked device; the attacks seem to rely on performing actions simultaneously to exploit race conditions much like weird glitches in games. This class of bugs is really hard to test for due to the large search space. Model checking might offer a solution, but it's not a magic bullet by any means.