Well I had an IBM DeskStar that started corrupting my Windows installation. It was in a "sandwich".
I blame that on my case temps which were 100F/ 40C at the time. (I wasn't aware that the front fan did nothing, since it was totally blocked by the front plastic of the case. There was no rear fan. Basically, the PS fan cooled the whole case.)
To answer the original question, a 5200 RPM HD is said to consume about 6 watts and a 7200 RPM HD 8 watts.
In summary, it's the right thing to do to offer your hard drives some cooling of some sort (at least a cool case) but most times you'll get away with not doing it.
the wesson
ps these days the deathstar is in my machine at work, serving as a spool/temp/repository drive, and doing fine.