[yogi_123rd]

It possibly can happen. The real question is does the CEL stay on after driving it a bit which would indicate a real problem.
I have noticed that the CES has come on a few times in extreme cold weather after about 5-10 minutes of starting the car with an Oxygen Sensor Fault code. It would eventually go out after driving it a bit. I know the ECM will delay doing the Oxy Sensor check after startup to give time for the exhaust system to reach operating temperature of 700 degrees.