I don't think they needed one - they knew where the phone was because of the GPS locater.
Honestly, anyone who LOSES a $1,000 phone needs to be slapped repeatedly. Hell, anyone who puts $1,000 into a phone deserves to have their head examined. But that's just me.
I found a phone laying in a parking lot a few weeks ago. I picked it up, charged it (the battery was dead), and took it home. I contacted the service provider (T-Mobile) and explained that the phone had been lost by the owner, and asking where I could turn the phone in.
The next morning, someone sent a text to the phone demanding its return to "where I found it" (in the middle of a parking lot? Um, no.). Apparently, the service provider had blocked outgoing messages on the phone when I contacted them, because I was unable to respond - I used my own telephone to respond instead, telling the sender where I'd found the phone, and that I would be happy to return it to the owner, or to turn it in to T-Mobile.
After several messages trying to make contact, I just took the phone to the local T-Mobile store and turned it in. I also sent one final message to the other person, telling them where and when I had done so.
I can't imagine if the police had broken down my door and accused me of stealing it. I guess at least I had proof that I was trying to contact them and return it, in the form of the text messages.