Possible they didn't put oil in it when they changed it last time? My 01 GMC front diff came dry from the factory. Seized at 15k miles and blew an axle shaft when it did.
Would be very unusual for a factory diff. But much more possible to happen at the dealer that they'd forget to refill after draining.
I think I have the record for front diff replacement. I'm on #4. But that's due to one tsb fix and then two ARB replacements and instead of a third arb install I went back to an open OEM diff. ARB covered the parts and labor on their stuff and Toyota covered the TSB. So I've only swapped them a few times myself.
None of mine ever left me stranded like the GMC. They never actually didn't work. Just made noise for various reasons. ARB issue was with their then-new spider gear forgings and they were just really noisy. Not a functional issue. But they were significant noisier than the Toyota needle bearing when it went out. So still kinda annoying.