filterObj = {}; for (let i = 0; i < 225; ++i) { filterObj["foo" + i] = 123; }
db.coll.runCommand({explain: {find: "coll", filter: filterObj}}) 

This was enough to trigger it on an optimized build on my machine. An unoptimized build will likely fair worse.

The implicit ANDs in the filter are translated in a way which makes each clause of the AND a child of the previous one (instead of a sibling). This is known as the "top level AND optimization." With such a deep tree, when each stack frame is large, it is quite easy to overflow.