At stolen in the box, they are not turned on, not listening to a network and cannot be updated. Not bricked. They cannot be connected to a cell network. They might connect to wifi.
I dpoke at length to the tech at a nearby Verizon that was robbed at gunpoint.
Apparently modern devices can brick themselves once they detect a cell or wifi when they broadcast their MAC address. And unless you are in the Himilayas such a signal will be found.
Even if they are older they can never be activated.
And any attempt to activate will broadcast the GPS location.
It is multilayered.