I'd say it is a possibility, but probably won't happen. I've only heard about one dying from an overnight hypo, that person often had problems with overnight hypos (her family had to wake her up with glucagon several times) along with other health issues if i remember it right, guess her body simply didn't have the strength to snap out of it again, she just didn't wake up one morning
But don't worry about it too much, the chance of it happening is very slim, at least as long as you don't just ignore the hypo when waking up from it...
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22 years old, diagnosed T1D on october 14th 2004.
On MDI, Novorapid and Levemir, using the NP4
Currently back to pumping with my IR1200, April 2008.
Been using D-tron and Animas IR1200 but prefer the pen