Sorry, I was digging on that too much time ago and haven't saved any links.
AFAIR, there is permanent busy state in certain conditions when functioning in SPI slave mode, unablility to reset TXFIFO/RXFIFO and some edge case with DMA and TXE/BSY when DMA failed and you don't know how many bytes are in RxFIFO.
Sorry, I was digging on that too much time ago and haven't saved any links. AFAIR, there is permanent busy state in certain conditions when functioning in SPI slave mode, unablility to reset TXFIFO/RXFIFO and some edge case with DMA and TXE/BSY when DMA failed and you don't know how many bytes are in RxFIFO.