You are suppose to put an automatic into park, before getting out, and many here likely do that and skip using the parking brake.
I started using the parking brake regularly only once I got the 2005 Prius; its park pawl had a wider range of roll than other automatics I've driven.
In this case, people, likely new to a Toyota hybrid, might be forgetting to put the transmission in park, and possibly even forgetting to turn the car off since they don't hear an engine.
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