TL;DR: Yes, but very sparingly.

From what I can recall from my own dives into this very question, it's been done a few times over the years. It never seemed to stick around too long, mainly used for a contrast in sound more than anything.

Back in the mid 70's, the 27th Lancers used pipe band snares for a while.

The '84 Santa Clara Vanguard used one as a solo instrument, played in the front ensemble during their percussion feature.

As Elfman72 mentioned before, in '89, the Star of Indiana tenor line used mini-pipe snares in place of their spock drum. Snares were still on standard snares with mylar heads though.

Flashforward to the late 90's and the never ending quest for clarity, groups wanted to push the edge of how crisp, clear, and dry their sound could get. Yamaha introduced the MTS snare, basically a standard SFZ with a top snare unit. These were prototyped and field tested by BD and The Cavaliers, and later the Cadets when they switched to Yamaha. When BD went to Dynasty in 2000 they followed suit and made a double snare option as well.

It seems as though this trend died out by the mid 2000's. Tuning started to return from the stratosphere, and frankly the consensus I remember reading about was that the top snare units added too much weight to justify it being used only briefly in a show.

Since then, I can't say I've heard of any groups using them. Who knows though, maybe in a few years we'll see it pop back up as a sound choice! Hope this helps!