Issues opening my, I mean, a friend's hood

Say a friend of mine leaves a socket wrench sitting over the wheel well of the engine bay and then closes the hood. After trying and trying, he can't seem to get the hood open even after having someone lean on the latch area while he tries the hood release. Do I, I mean, does he have to now remove the bumper to open the hood? Thanks!
Comments
Don't worry my "FRIEND" has done this many times.
You might be stuck pulling the bumper off though.