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It was a big enough problem that technological solutions were invented to solve it: https://www.wikiwand.com/en/Safety_coffin https://www.wikiwand.com/en/Safety_coffin It still happens today: http://www.businessinsider.com/man-rescued-after-being-buried-alive-in-brazil-2013-11 http://www.businessinsider.com/man-rescued-after-being-burie... Bodies can also move from gassing or various parts of their nervous system being prodded shortly after death.