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Yes it most certainly can. On older Rear wheel drive transmissions, namely Ford C4 transmissions, there is a vent at at the very top of the case. If you try and fill the transmission while it is idle (no moving parts inside, like on a test stand or in your car that is turned off) you can easily fill the case and have the fluid start to overflow. Tjhe proper technique is to fill the transmission when the car is IDLING and in D or N. Park may not allow the torque convertor to fill and this is where the majority of AT fluid is stored. So if you are in P and the motor is turned off, the fluid may bypass filling the Torque convertor and end up coming out the top vent. On modern FWD transmissions, you fill the AT through the dipstick while in the position the dipstick says to test in, ie. D or N. When doing a pan gasket or filter change, it may take only 2 quarts to top off as you are not draining the convertor. It is also bad to overfill a modern AT as it may cause foaming or cavitation of the fluid, and that causes slippage, excess wear on the actuator pistons or servo's and mainly the ability to remove heat from the transmission, the prime enemy of an AT.

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Q: Will a transmission leak if too much fluid?
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