I'm sort of thinking through this as I type.Sure it can, you just need to be able to set the correspondingly higher pressure in order to reach the same saturation level at equilibrium.
Kegs are rated for pressure that are more than adequate to fully carbonate beer at ambient temperature. After all, that's the temperature commercial beer is usually stored at until it's time to start serving it. Back when I didn't spund but force-carbed in kegs I could see first hand that carbonating ales at ambient temperature using the set-and-forget method was at least twice as fast as the same process at lagering temperature.
Water's (and consequently beer's) viscosity is lowered by a factor of about 2 going from 0°C to 25°C plus there is a small increase in absorption and diffusion rates due to the increase in molecular kinetic energy (about 8%).
So, warm beer will absorb CO2 more quickly than will cold beer, but cold beer will hold more CO2 than warm beer? Is that what we're saying? What are the implications of that? If I force carb (set-and-forget) at room temperature, the beer will equalize CO2 more quickly, but higher pressure will be required to push it into solution. Once I chill that beer, less pressure will be required to keep that CO2 in solution, but the same overall volume of CO2 is required. So, it appears that the only benefit to chilling first is that you can use a lower pressure (which is not really a benefit), and the benefit to carbing warm is that it will be carbed sooner.
Back to my original question, though: there's probably negligible difference in chilling before applying CO2 and letting it chill while carbing.
We're getting close to needing to move this to the Brew Science forum.