Absotively - I always pull the ground (first) rather than +12. There are some other delightful failure modes as well, such as your big college ring or metal watchband coming between that wrench and ground.
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Although not impossible, it does make the job a lot harder to do in-car.
Lots of bending over the fenders, or reaching up from under the car.
Murphy's Law states that if one head gasket goes, the other side is not far behind... you may be doing the other side in the near future!