In the early days of smokeless powder, around 1900, das "Loseschiessen" or "shooting loose" was a definite concern. I happen to have some volumes of "Das Schiesswesen" from that time, and there is quite some complaints and discussion about break action guns getting wobbly with the new smokeless high pressure cartridges.

In that time were hunters and gunnmakers (the conservative lot, I think) that still preferred to stick to black powder, and push this to the limits of practical use, as with the 9.3x82R or even bigger cases.
Other gunmakers, such as Jäger, Schrader and Brenneke worked on more stable break action systems.
I feel the amount of work that went into these sophisticated and difficult-to-produce actions illustrates the need.

Here is an article on the Brenneke action for further reading.

http://ezine.nitroexpress.info/NickuduFiles/Africa-PDF/Africa334.pdf

Regards,
fuhrmann