Perhaps. I've seen it mostly around dogs. I had a German shepard that loved to dig under his kennel, so we buried fence under the entire thing. Next he learned to climb the 8' fence. So we added electric wire around the top and bottom of the fence. That worked for about 3 weeks. Somehow he still kept getting out. It took us another 2 weeks to catch in in the progress of escaping again. He would push his hind quarters against the fence, ( I guess it didn't hurt so much) until the fence shorted out. Then he'd happily climb over. We eventually had to put a roof on the thing. Unbelieveably intelligent.
Before everyone gets all upset, his kennel was quite large and I took him out to play with him several hours a day. We'd go romping through the woods all the time. We just couldn't let him run loose, he definitely wasn't an inside dog, and there's NO way I was going to chain him up.