I have seen errors of more than 10000 km. I was looking at network
fixes which come from cells and wifi only, no gps. The fix put me in England (UK) somewhere even though I was at an outlet mall in California (US). My guess is that someone had moved their wifi server from England to California and the Google WiFi database had not updated itself yet. I had a few more errors like that but not as spectacular, only 1000-5000 km reporting locations in other states of the US.
Network fixes based on cell towers will usually be 1 km off and are often 10 km off. These are based on the cell tower seen by the phone, and in hilly terrain you can often miss the closest cell tower and grab one that is on a high location a few km away.
GPS fixes also can have errors, but usually less than 1 km. These errors mostly come when some GPS signals are blocked by hills or buildings or reflected off nearby hills or buildings.
I have seen all of the above when testing Android phone positioning. Not all phones will behave identically, the quality of the GPS implementation (chip choice, rf design) can make big differences in performance.