I've only had it happen once several years ago on a very-long alternator bolt. It was another hard-to-reach thing and I was paying too much attention to getting it out vs. where it was going as I did. It was longer than I thought, and I was lucky I was able to get the wrench out by moving the radiator a bit on its mounts.
I won't make that mistake ever again, though I did come close on the upper control arm mounting bolts on my Mini while using my SK X-frame reversible. I do like switchable though if I can get them.