Keep in mind, it is the combination of the Plane rotation and the tablet rotation. The plane could be banked 20-25 degrees, then add an extra yoke correction for wind gusts of another short burst of 20 degrees, it would rotate the screen briefly.
Also, in a high crosswind slip or heavy turbulence. I've landed my 172 with full rudder and aileron deflection before, and it would definitely rotate in that situation. My iPad Min and my Android tablet rotates at just over 45 degreed.
Agree, it would not happen that much. But you'd sure that to have pilot slipping in with IFR conditions and high crosswinds and the screen rotate on them. Again rare, but possible.
I'm sure Walter will take all the feedback into consideration. We have to think of all pilots and situations. Good dialog here.