A lot would also depend on the wind direction, in relation to the bike stand. Like most, whenever parking with the bike on the kick stand / side stand, it is best to put the bike into 1st gear plus cock / lock the steering, to prevent any forward movement. If the wind direction is towards the side stand, there is less chance of any wind causing the bike to take a nap. However, if the wind helps take the bike weight off the side stand, either through strong winds or the cover acting like a sail, could be enough allow the stand to give way. Then there is the type of surface that the stand rests on. It may sound like a lot of hogwash, but most of the long time riders take this into account automatically.