Yup. I've seen it several times where a bit of the tube gets caught between the tire bead and the rim. Sometimes it holds at full pressure for several minutes before it blows. It never fails to jolt your heart when it goes.

The most common way to trap a bit of tube is near the valve stem. There is some reinforcing material around the stem that makes it want to stay flat and wide at that point. I make an effort to be sure the tube is inside the tire bead at that point. Generally, after the tire is fully seated and before I put any air in the tube, I push up on the valve stem and make sure the tire bead is well seated all the way around the rim.