I suppose, amazingly, It's never happened to me. And I use to pump my 23mm and even my current 25mm tires up to 125 - 135 psi. I don't routinely do that anymore, so lets not get into that.

I have traveled with my bikes in the car and fully inflated tires. Left in the noon sun during lunch stops. And I've left my bikes in the sun when at events. I guess I just haven't had the proper conditions in the 60 some years I've ridden.