My observation has been that it's a question of timing. Rapid growth, cool nights heating up to warm temps during the day combined with those juicy stalks all equal snaking. With the intemperate and unpredictable weather in my area, I've seen it a lot. Some cultivars are more prone to it than others, but caught in the right stage of growth I think most can/will do it. It's particularly a problem for me growing ABs because they bloom earlier in the bloom season, have a tendency to have really rapid growth compared to TBs and the early season is definitely inclined to have those temp swings between cool and warm. Wind aggravates it, but wind alone won't cause it. They may lean over, but the stalk will be straight rather than curling around. When I've had too heavy a hand with fertilize and the temps start swinging, TBs that don't ordinarily display the trait will gooseneck the same as the ABs earlier in the season.
Texas Zone 7b, USA