If yes, I would like to see an example of that (that works on systems with very minimal lockdown, i.e. using the device control group and kernel capabilities).
Otherwise, if you just mean that "0-day Linux root vulnerabilities can be used to escalate from non-root to root in a Linux Containers", that's a truism, and it also stands true for VMs or OpenVZ systems.
Just like 0-day vulnerabilities will help people to escalate from non-root to root in a FreeBSD jail or Solaris zone.