I can't think of an example, and I would also be interested to hear of any that others can come up with.
However, what you can find are cases where the user doesn't really care much about robustness at all if it impacts performance. (Compiles, for example; I can imagine a compiler "safely" overwriting the output object file so that it doesn't leave a broken environment after ctrl-C. But the user might be happy to "make clean" after a system crash.)
So it may be legitimate for a filesystem to behave in this way iff there is a performance benefit.