In the context of breaking into phones and laptops, "state-level actor" usually implies a team of people with NSA-type forensic capabilities. That is, they have deep expertise in infosec and related topics, access to 0days that the security apparatus has hoarded and kept secret for their own use, and they may have bespoke hardware to facilitate attacking the device.

A random cop might have access to a Cellebrite machine but they can't just call up the NSA and ask them to break into some drug dealer's macbook.