I bet this is a lot more likely with international applicants simply because there are probably more highly qualified international applicants than there are available spots. For example, if an international applicant applies to the top 10 schools and has an excellent application, but each school has ten times as many similarly qualified international applicants as they have spots for, then I could see something like that happening.
For domestic applicants I would find that much more surprising. If you're Harvard or MIT caliber, you're probably getting into a few more good schools as well. But anything can happen, really.