Very possibly. I’ve also seen some that were not completely tamped down, or ran over a few that clanked loudly when cars ran over them showing they weren’t secured.
I suppose it could happen if the manhole rim was warped, or working loose from its bedding in the pavement, or if somehow a manhole cover got bent slightly (if that’s even possible). Seems extremely unlikely, though, if everything’s straight and true and properly installed.
I’ll probably never know.