I have had it happen. Not often but more than once. You watch the little bugger squirming and wiggling and see it pulling its head back, but not going inside the egg. It may have been in eggs that self pipped I don't recall.
I used to buy gravid females and then hatch out the babies a loooong time ago and I also bred a few of my own but I don't recall where I saw it, just that I did. I don't remember if I ever had one die from it, but being stuck that way and getting panicked could lead to choking. At least it seems that way to me.