I've seen them (specifically, filenames generated from values in a "modern" configuration language - json or yaml - that mistakenly had newlines in them.) Fortunately, most of the shell tools involved used `-print0` and the related options anyway (because once you have humans involved, it's the easy way to handle normal spaces in names) and the things that did break, where only "some low-value data processing got skipped" rather than anything harmful.