I believe this was mostly on the older Model S that didn't have a dedicated coolant pump. It would always run at a fixed speed which was fine for normal usage but not on the track. New Tesla's have added a dedicated small electric pump so it can run at the speed needed to keep the motor in the correct temp range.
I'm sure they can still overheat based on other limitations (coolant radiator, pipe size etc...) but these can be rights sized based on trim level.