I guess anything possible. But as I started earlier. If you take extreme care holstering, then that still wouldn’t happen. Which is how we instruct and train. Very slow movements, make sure the holster is clear of any instructions, then gently guide the gun into the holster while looking at what you’re doing.https://www.itstactical.com/warcom/...her-holsters-can-cause-accidental-discharges/
This made me think of this story from 2011 when a worn-out Galco holster got into the trigger guard and manipulated the trigger.