I would suspect so.
If I were younger and played tennis as I did back in the old days (the 60's), I'd drop one of those little dinky underhanded serves in there quite often.
Really ......... what can the returner do with it????
If it is done well (disguised well).... the returner can do little else than to get to the ball ....... and lift it over the net.
Really..... what are your thoughts on this?
Michael Chang won the French Open semi-final against Lendl serving underhand.