Yes, but when you get a phone under contract you can't return after the contract takes hold, which for some carriers it's 14 days. On AT&T it's 30 days, so he would have 30 days to return if he gets it under contract, after the 30 days he can swap it out for another until he hits 45 days, but because the contract can't be cancelled after the 30th day you can't return it.
First and foremost, this is just complicating the situation. The OP is asking about the return policy if he were to buy the phone
without a contract, so the Best Buy return policy is the only thing he has to worry about.
Second, Best Buy and mobile providers use their own policies, they are separate of each other, Best Buy just acts as a hardware provider. The link I provided states that the customer is responsible for cancelling any cell service that was created by buying a phone on contract through Best Buy. What that means is, if you were to buy a phone through Best Buy on Verizon (since they have a 14 day policy for example) your contract would be locked in at 14 days
with Verizon but the customer could still return the phone
to Best Buy regardless and the user would either have to (1) cancel their line with Verizon and pay the ETF or (2) go back to their old phone and lose their upgrade. But most carriers usually can be negotiated with in some circumstances.
So technically, since he bought the phone at Best Buy, he would either have the 30 or 45 days to return it, dealing with the actual contract with the cell provider is the customer's problem.
From the link:
Returning Mobile Phones & Devices with Plans
When returning a mobile phone or device with a plan, you are responsible for ensuring that your service is canceled with the carrier. If you don't cancel your service, you may incur additional charges from your carrier. All carrier charges are your responsibility.
But I do understand your point, who would want to pay an ETF or lose their upgrade? It's all very convoluted. This is another reason why I usually emphasize consumers to be more aware.
