I’m talking about the earliest cases. The earliest references depend on the particular standard of crypto. KeeLoq is a very famous rolling code standard where attacks go back to 2007 and earlier.

RollJam is known since 2014 [1]. It was popularized later through a custom device [2].

[1]: https://spencerwhyte.blogspot.com/2014/03/delay-attack-jam-i...

[2]: https://www.wired.com/2015/08/hackers-tiny-device-unlocks-ca...