Possibly, but really min-maxing is always possible, its just stretching the army composition rules as far as you can. Its not like theres no min-maxing in fantasy. In fact a seriousy min maxed army in fantasy can be more powerful than the 40k equivilent in many ways. For example, the most simplistic Fantasy min max is the gunline, with 4 spellcasters in support. Some armies will just crumble to it. Also a mate of mine said when he went to the fantasy GT a few years ago he faced all min max armies in one form or another including a VC army with a few small units and a large 200 strong zombie unit with all the armies characters in it