  For temperate exoplanets orbiting M dwarf hosts, the proximity of the
habitable zone to the star necessitates careful consideration of tidal effects.
Spin synchronization of the planetary orbital period and rotation period is a
common assumption for habitable zone planets across the entire M spectral type.
This predicted tidal locking has important implications for conditions on the
surface. In this manuscript, we investigate the plausibility of capture into
Cassini State 2 for a known sample of 280 multiplanet systems orbiting M dwarf
hosts. This resonance of the spin precession and orbital precession frequencies
is capable of exciting planets into stable nonzero rotational obliquities. A
large axial tilt resulting from this predicted resonance capture can preclude
synchronous rotation, inducing some version of "day" and "night." Considering
each planetary pair and estimating the spin and orbital precession frequencies,
we report that 75% of detected planets orbiting M dwarfs may be plausibly
excited to a high obliquity over long timescales. This is consistent with
similar findings for planets orbiting close-in to FGK dwarfs. However, it is
only for M dwarf planets that the parameter space relevant for capture into
Cassini State 2 overlaps with the stellar habitable zone. This effect is
strongest for host stars with effective temperatures $T_{eff}<3000$ K, where
more than half of planets with $T_{eq}<400$ K could possess non-zero obliquity
due to residence in Cassini State 2. This overlap renders the potential capture
into Cassini States extremely relevant to understanding the galaxy's most
common temperate planets.
