With the tools they include in the car and how hard it is to get to the spare tire (in some models), I would be hard pressed to get the wheel off (especially if some shop decided it would be a good idea to really overtorque the lug nuts with an impact wrench).

In fact, the last shop that worked on my car did exactly that and I had to buy a breaker bar and stand on it in order to loosen the lug bolts on my car before I retorqued them to the correct value.