"Power" is always such a relative term to me when it comes to gaming. To some purely reaching the technical limits of a console could be definitively "maxing it out" and I'm sure any top notch developer could do it quite easily and has encountered limitations already (as proven by games like Halo 3, MGS4, and etc where resolution changes have to be made as well as drops in frame rate).
The real definition of "maxing out" a console to me is taking a ton of factors into consideration. Its completely stretching the boundaries of whats possible in that generation not only in graphics, but in gameplay, the size of the world, content, and etc. And I think that there isn't any such time that such a game is made that completely does this so much as that the overwhelming majority of developers out there have worked on enough next gen projects to ultimately have the knowledge and urge to move on to better technology.