Some snails most definitely will not be able to right themselves. Turbos & Astraeas mostly, from what I'm aware of. Its from their squat, conical shape, they are unable to get a good grip beneth them to right themselves. I read an article once where one aquarist let them be after they fell over, but they'd eventually starve to death. I've lost a few myself because they've fallen off in the back & I never realized they were in distress
On the flipside (*boo!*), I have also had some snails that I could swear were giving up on life. I'd find it dropped off a rock & upsidedown, & I would right it, maybe even place it back on a rock (I mostly right them & leave them on the substrate now because of this), only to find it upsidedown again the next day, or maybe only even a few hours.
I don't think this should be confused, though, with snails that go 'dormant'. I had a Red Footed Conch that I could've sworn was dead (right side up on the substrate, but not moving for several days), but it turned out it was making a baby-- & I really don't know how exactly this could work out, but it was the only one of this type in the tank in particular, & one day I noticed it trucking around again. Then I took a small piece of rock from this tank to put in my QT, & find a juvenile on it. Asexual reproduction? Who knows? (beside the happily grinning snail
)
So I guess my 2 cents is, if its upsidedown, & doesn't smell like rotten eggs, turn it over. Good luck...
Pete