Icloud locked device

I would first like to say that the icloud activation lock is the best security app out there, it does do what it is supposed to do. Now my question is just out of curiosity because I had a friend who had acquired an ipod touch from her brother that had passed away she was power of attorney over his estate and the ipod touch had not been stolen her brother was the original owner she was with him when he purchased it 2 months before he passed. Anyways long story short she factory reset it not knowing about the icloud lock and ended up throwing it away. What would someone do if the original owner has passed away? How would they go about unlocking it? Or is there no way to do so? Like I said I was just curious because I'm sure that there are a few people out there with a similar situation.