Yes there are situations where it is justified, but we shouldn't draw that conclusion with knowing all sides.
I don't know any details to question legitimacy of the issue, however in my experience I am constantly surprised how many times it is just communication breakdown or gap in what each party perceives.
Also the pandemic has made things more stressful for everyone and outbursts do happen with more frequency perhaps it is easier virtually to shout at some one i suppose.
Torvalds was known for his infamous roasts on LKML, he only goes on a triade when he feels the situation warrants and person should know better. That doesn't make it right , but someone had to really explain it to him before he toned it down recently. I don't think his intent was ever to be toxic or aggressive.