Fluids are covered under a warranty provided they are being replaced due to the repair. I`ve yet to see any warranty deny fluid if it was being replaced as part of a repair.
And yes I do believe the first "rcomended" service is 100k miles. but as I have said the fluid is cheaper than a trans. and even if you say "well I have a warranty" its still better than sitting on the side of the road waiting for a tow truck. and potentially ruining a vacation. granted this failure isn't the result of a missed fluid change, it just shows that when fluid gets hot it should be replaced.