I don't count but if it's obvious that it's over 10 items, it peeves me bad.
I saw this lady (late 50s - 60s) at the express checkout with a whole basket of items, it was about 30 items! I was so mad and she knew she was over the "10 items or less" limit but she didn't care because obviously she knew that no one was going to say anything because she was an old lady