Depends on the car and where it's drive wheels are. Also I think tow drivers are authorized to use a tool to break in to the car (non destructively) to put it in neutral if necessary.
Aside: if you ever notice a teeny tiny panel that has a dimple or hole to open it with by the shifter, that's the release for the interlock that prevents changing gears without the keys. That's how you get in neutral when the owner isn't present.
