I've seen weirder positional asphyxia cases before, but they all have some factor that severely impacts one's ability to right themselves; usually intoxication but also physical disability, old age, etc.
If it's the type of recycling bin that's usually kept at the house (the one that's about chest-height on wheels that you push to the curb), I have a hard time imaging how a healthy 61-year old could get totally inside and not have the ability to push with their hands or knock the bin over. But again, weirder things have happened, and LE hasn't mentioned if tox was positive or not.
Was it ever released what kind of bin it was?