Beyond their impressive sampling capabilities, score-based diffusion models offer a powerful analysis tool in the form of unbiased density estimation of a query sample under the training data distribution.In this work, we investigate the robustness of density estimation using the probability flow (PF) neural ordinary differential equation (ODE) model against gradient-based likelihood maximization attacks and the relation to sample complexity, where the compressed size of a sample is used as a measure of its complexity.We introduce and evaluate six gradient-based log-likelihood maximization attacks, including a novel reverse integration attack. Our experimental evaluations on CIFAR-10 show that density estimation using the PF ODE is robust against high-complexity, high-likelihood attacks, and that in some cases adversarial samples are semantically meaningful, as expected from a robust estimator.