It's a little bit less clear cut than getting rankings the right way or wrong way. I personally know many churn and burn blackhatters, and the eventual demise of their domains is just part of their business model.

Google has never been good at handling short term black hat spam (buy viagra is the colloquial example always). They are good at filtering sites out after they've been ranked for a while though.

But when these blackhatters are making tens of thousands of dollars a day with their short term rankings, it's hard to convince them that they need to be focusing on the long term rankings avenue...