Many filters for me, never seen this happen... but I don't doubt it's probability in the future. I definitely shy from the Fram filters, but it's always been because of cheaper quality innards. All the same, I've never spent the top shelf price of the "high end" filters.
Something to add to Old Mechanic's rules is, if possible, prime the new oil filter with some of the new, fresh oil. My Mopar engines, luckily, all mount straight-up, so I can fill them to the top. If it went in sideways at all, likely wouldn't be possible to prime. After you fill it, you'll likely have spilled a bit of it on the O-ring seal anyways... just run it around with a clean finger from there!
