Was she filing an older tax return ? ( who charged her the fee??) Yes, by law the W2's had to be mailed out by February 1, 2010 (because Jan 31 was a Sunday). If your friends employer did mail it, but her address was incorrect, that is not the fault of the employer. it's up to the employee to provide the correct address..... if that's the case and it was the employer who charged a fee to reissue the W2, then yes, it's well within the employer's rights to impose a fee. If it was the IRS that imposed a fee for a late W2, I don't see how they would know this considering tax day isn't for 2 more days..... she's not late filing her taxes because of a W2.
The other thing is, if your friend filed her taxes without her W2 form, she did so at her own risk because there are things on your W2 that have to be accounted for such as pre-tax deductions, medical, 401K, etc. You didn't say who charged her the fee for a late mailed W2. If her employer DID mail it, but to an incorrect address and they reissued the W2 last week, then it's not the fault of the employer. The employee needs to make certain their address is current. (even with a past employer if you are getting a W2.)
Personally, I've been on the W2 side ....that's my job. We charge our associates that aren't with the company any longer to reissue their W2. If you move, we have no way of knowing that unless you tell us. We can only mail it to the address we have on file....if the post office doesn't deliver it or forward it, we don't have any control over the Post Office. So it's hard to stay on top of getting a W2 delivered.