The filter access is poor on my Lincoln LS. I always put the filter on hand tight, but have always needed a wrench to get it loose. The location of that particular filter(very bottom of the engine) usually results in it picking up a lot of grease, oil, road crud, etc on the outside of the can and I find it hard to get a good grip.
Generally I just need to barely "crack" it with the wrench, at which point it will unscrew by hand with ease. If there were more clearance for me to get a good grip, I might be able to get it off without a wrench, but I don't see any point in beating myself up over doing it.
My MG has the filter sitting right by the engine. I've only changed the oil once, and have no idea how long the old orange can had been on it or who put it on. It took quite a bit of grunt to get it going, and even an occasional assist from the wrench in coming off. The new one(Motorcraft) went on with ease. I'll probably change the oil again sometime this spring, so I'll see how easily the filter I installed(hand tight) comes off.