Modern OSes are journaled filing systems. They leave bits and pieces of data all over the place. Not everything is always cleared out of memory, and when solid state becomes the standard it will be even more so the case.
I am not saying it is always possible, but I am also saying its not impossible either. It just depends on a case by case basis. It all depends on how much it has actually been overwritten. Which is why secure delete programs do random write 0s over 8 times in a row just to be sure.
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