This is exactly why starters for liquid yeasts should be made. After a couple experiences under-pitching higher-gravity worts I convinced myself it would be a good idea to make starters, if only to verify the yeast was still active.
Here's one of my experiences ....
Had a brew with an OG of 1.066. Pitched .5l of WLP001 to 5 gallons of partial mash. It was a definite under pitch. The under pitch wasn't the only mistake. Didn't shake the wort and even though it fermented ok, the priming was done in a bucket. Bottled a bit early and didn't get a good finish, so some bottles were over-carbed, some flat. Many were way sweet. <sigh>
Live and learn. Yep, and bad yeast from the brew shop... Like Gump said, it happens sometimes.