An individually frozen record whose containing record group meets the disposition 'destroy' requirements can still be destroyed. I froze a single record of a group of three. I navigated up to their containing folder, cut off the folder, and could destroy the folder contents including the frozen record. All that remains of the record is the audit log, which is still frozen and cannot be manually deleted until the hold is lifted.
Much like how a delete command will not delete a anything inside a folder when a single frozen record is inside, the destroy command needs to perform a similar check to prevent inadvertent destruction of frozen records.