It is extremely common in the practice of citations. What you see written in a paper is:
“Intervention X can help patients with condition Y (Smith, 2012)”
But when you actually read Smith the result is couched in limitations, or maybe only holds under some circumstances, or maybe uses a weak methodology that would have been fine for Smith but isn’t appropriate for the current paper.
There just isn’t room in that sentence to reflect the full complexity, and the simplified version is all too easy to slip through peer review. Sometimes papers form chains and networks of oversimplification with each citation compounding unwarranted certainty.