It depends on the difference in width between the rim's brake track and the inflated tire. When you pop a caliper brake's quick release, the brake opens by a certain amount, not to a certain width. If your tire measured 32mm wide inflated, and it was on a hypothetical rim with a 32mm-wide brake track, then you could easily remove and re-insert the wheel without popping the QR at all. If your tire measures 32mm wide inflated, and it's on a skinny rim with a 20mm-wide brake track, then very few caliper QRs are going to pull back the pads by enough to make the tire release cleanly.