Not yet. Wouldn't be surprising, but most of the time the problem is "person holding the remote wants it to work, connects it to wifi when it offers, doesn't know that they shouldn't".
Enough people connect their TV/smart devices willingly to the internet that there is no need for adversarial approaches like this (which are not trivial to set up - they'd need to maintain per-country partnerships with Wi-Fi hotspot providers, pay them and hope the ROI is worth it).
Similar FUD is being spread around HDMI's Ethernet channel; a way to carry network data over an HDMI cable. I have basically never seen it in the wild on any consumer device, but even if it were, it would still require the other device to cooperate and act as a switch/router to share its connection to the TV. Yet despite that every time smart TVs and privacy comes up someone mentions this.
That’s certainly admirable, but haven’t tv manufacturers beeen caught connecting to ANY WiFi they find, if it’s open? Amongst other various dark patterns?
Your statement here kind of characterizes it as user error, but the manufacturers are absolutely hostile actors here.