Hello keva,
Yes they can but both ways would require documentation.
There's this way:
How to request access to a deceased family member's Apple account - Apple Support
Then there's this way:
Reset device:
Apple can completely reset a device if a person can provide sufficient evidence of valid ownership. This is done online at: Activation Lock support request - https://al-support.apple.com/#/additional-support Apple says, "Proof of ownership documentation is required," but does not provide details in the article as to what is acceptable proof. Prior to this official service Apple typically required the original receipt* issued by Apple or an Apple Authorized Reseller and documented provenance. Typically it would be the original owner who does this, or a descendant with legal proof of ownership and proof that the deceased person actually owned the device, such as a receipt. Because they would likely require a receipt you may find the first way more accommodating although it does involve more legalese. the first way would also mean you would have access to some of the content on the device.