since ios 16 i have more than a few times. i do think its related to me pressing the button to stop the podcast, and the phone getting confused having decided to stop the podcast and then taking the button press to play music, but sometimes it plays the most random music that i havent played in years so its not like its continuing.
also on thinking about it, when sometimes im in the office and i open something, maybe a game and it blares loud, and i hit the switch, and some games it mutes it and some it doesnt.