This has to be enabled on the device (I believe it does not come enabled via default, and she could have "Location Services" turned off for privacy anyway), and the person has to be technically savvy enough to have done so. If they have, I'm assuming most PDs are smart enough to tap into that info somehow, but maybe this is a bad assumption on my part.
IF she had an iPhone, and IF she had Location Services/Find my iPhone enabled, then yeah, there are lots and lots of stories of LE finding stolen Apple goods that way.
Quoting myself. On that note, a reasonably tech-savvy perp could turn off Location Services himself (although just turning the phone off seems more effective, shrug, I don't pretend to understand the criminal mind and this case is so weird).