I doubt it has, because no ones really fooled around with it. There's also the fact that only a select few are blessed with a low duck like Jigglypuff. Pikachu is already one of the best characters in the game, so it really won't make him any difference. Jigglypuff, on the other hand, is the lightest character in the game, and as such needs to avoid as many attacks as possible, so her low crouch is a very valuable asset. There's also the fact that a ducked attack could possibly mean a Rest, and damn is that satisfying. It's like a martial art. Crouching Balloon, Hidden Jigglypuff. It's not just Samus, though. Puff can duck under a lot of people's projectiles and attacks. Samus just happens to be cursed with high hitting attacks. Seriously, only her down smash, Plasma Whip, and down tilt can hit a crouching Jigglypuff.