This seems orthogonal to internal implementation hiding, especially if the "API" is not a public library API, say, but an internal one.
Then again, contracts about who can modify what data are also part of any public API; historically, there have been plenty of (quite decent) APIs that have returned pointers to internal structures that have limited lifetimes, in languages like C that don't enforce lifetimes at all.
Then again, contracts about who can modify what data are also part of any public API; historically, there have been plenty of (quite decent) APIs that have returned pointers to internal structures that have limited lifetimes, in languages like C that don't enforce lifetimes at all.