Some people in this world have for one reason or another encountered really bad press for there actions. Google can be a bloody nightmare to disrupt negative press from. In fact its long been rumored that the algorithm tends to favor negative pages (OK not really, I am sure its just a correlation to links)
With an increased effort by Google as of late to place varied search results into the SERPS and the roll-out of Google suggest there are a myriad of ways to get slammed.
Lets take the following 4 people for example: