IF they are new fish you just added, perhaps the fish died from something else and just ended up in the filter.
Even my 200gph HOB filter doesn't suck hard enough that even my smallest (healthy) fish get sucked up to it/stuck. A weak, dying fish...then yes.
I had a 20g Whisper in-tank filter in my last tank...my 1" long juvenile rainbow shark used to climb up inside the intake and used that for his hiding place. He could swim in and out all day long with no issues.
Again, I would guess that it was more likely a sick/weak fish that got stuck, so the COD couldn't be blamed entirely on the filter.
If you are concerned, however, you can put a sponge over the pickup tub of an HOB filter to help keep fish from getting stuck.
What are your water parameters? Is the tank heated? (what temp) Do you know about the nitrogen cycle?
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