
Yup, sometimes.
Also, sometimes laying on their side can be a sign of oxygen poor water. If she hadn't just had such a big meal, I'd suggest making sure that the proper amount of air is getting into the water, just to be safe, but it was probably the big feed she had.
And to confuse things even further, sometimes they just do that for no particular reason at all. I had one once that took a liking to laying completely over on his back. There was absolutely nothing wrong with him or his tank. I think he just liked doing it. Nearly had a heart attack every time I found him like that. They're kinda crazy animals.
Really sorry about the loss of your other cray, though. It always stinks to lose a cray.