I was thinking of a notoriously harsh module series; on some of the deeper levels players are denied their Reflex Saves while in sets of narrow tunnels. These same tunnels provide a penalty to attack rolls etc (depending on PC size) so it didn't seem out of line to deny the save as well -- the idea is that you wedge yourself in the tunnel and then squirm towards your destination.
I thought it was a neat rat-bastard trick, so I don't much care for the ruling that you can Evade even while unconscious. ;-)