I have been consistently told by my guidance, including Archangel Michael, that this is never the case. All stuck human consciousnesses are for sending on, and no matter whether they want to go or not - except that the situation is complicated with regard to human spirits attached to people. In that case there is commonly but certainly not always a karmic issue involved, and it is then generally necessary for a healing session in which the affected person is made aware of the reason for the attachment (usually a past life situation) before the spirit is allowed to be released.