I do think so – as long as the residue is broken down enough to be easily penetrated in spring. They are adapted to live under a litter cover and should thus not be bothered by mulch. They go dormant once the shade under the trees is deep and this is the condition, where the standard weeds do not thrive too well any more. (I do not have a clear picture about the amount of shade in standard dwarf tree orchards).

If they are used as a mixture I also would not expect gophers to multiplyas some species have toxic roots/rhizomes (probably as they need to deter soil dwelling feeders). In the case of allium ursinum the garlic taste keeps them away.