Last winter I decided to hit the Touchless car wash on my way to work after several days of snow and salt. It was about 20 degrees outside. After the wash, with the car running in park, I couldn't get it back in gear. After a few minutes I could move the shifter again.

I am guessing that the shift linkage froze up from the water. It has only happened once in 6 years, but I don't go to the car wash anymore if it very cold.