iPhone is disabled message

I just got home after two flights with a 4 hour layover in an airport. When I took my phone out of my pocket, it said “iPhone is disabled, wait 15 minutes”. I know this can happen if you enter the wrong password too many times. But, I used the phone during the layover, and the phone was never out of my possession. Is it possible that someone was trying to remotely enter the code incorrectly, or is it more likely that somehow the passcode screen was active while in my pocket?

Much likely the latter. I just saw someone else talking about pulling their phone out of their pocket and finding this.

They disabled “Raise to Wake” and it solved the problem, although that is fairly inconvenient.