Yes. These are extremely rare. Some models, like iirc a galaxy note and MacBook Pro have been singled out. The surface and airflow also matter. A laptop kept on a desk spends very little time charging at a time and any heat is dissipated efficiently. All devices are designed with the best thermal performance they can have.

There was actually a house fire a while ago not too far from where I live that forensics said was started by a device in a charger at night. For some units and some uses, they still fail.

Anyway. I think the better safe than sorry is warranted.