Not reeeeally... I've seen single MOSFET and IGBT dies bigger than the inside area of a TO-3. More likely it was contemporary yields.
Don't know what the largest BJT die is, these days; might not even be one as large, just because there's so little demand for them.
Tim
Same problem with MOSFETs. IXYS uses graded threshold voltages to tackle this problem (high threshold in the center) for their linear MOSFETSs.
All others - same story, with hotspotting in linear mode. See NASA, Spirito Effect.
The "reeeeally" being, most transistors that size are made for switching, so may have awful SOAs. The power dissipation is there, no contest, just doing it at voltage is harder.
That said, many newer MOSFETs, and even some IGBTs, are specified with DC SOA. However they've approached it -- graded threshold, tempco hackery, ballasting*, whatever -- it's done the trick.
*Probably not that, because source/emitter degeneration would severely eat into the saturated performance.
Tim