Engadget runs a feature every few months on the best smart phones for various price ranges by carrier. Their choices have seemed to make sense, at least for the past few years.
If she isn't "techy," then iPhone 4's are inexpensive now, and the 4s is a great phone (and I refuse to buy Apple).
I just went through the market in May, but my criteria are probably not the same, e.g., I wanted LTE, Android, and a high-density ('retina' in Apple - speak) display.
ETA: http://m.engadget.com/2012/04/02/smartphone-buyers-guide-spring-2012/?icid=eng_search_art
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