If you have had a Google manal action penalty removed from a website, you might want to recheck and see if any of them have shown back up as a penalty in Google Webmaster Tools. Some are reappearing after having manual action removed following a successful reinclusion request.

Any reason why this is happening +John Mueller?  Seems as though it's a bug, but affecting numerous websites.
If you have had a manual action spam penalty lifted in Google Webmaster Tools, yet aren’t seeing an expected bounce back in the rankings, you might want to have an other look at your manual spam actions in Google Webmaster Tools once again. It seems that some penalties are showing back up, even after a …
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This should be pretty rare -- but sometimes it can happen for a good reason. For example, if the webspam team can recognize that a linking issue has been mostly cleaned up, but still sees something that needs to be taken care of, they might switch it to a partial action, so that only those remaining, problematic links are taken care of, without affecting the rest of the site. Usually that's a sign that you're on the right track, that you've convinced the webspam team that a full manual action is no longer necessary.
+John Mueller Slightly different issue here.  The penalty is removed after cleanup and reconsideration request, all is good.  Suddenly it reappears, but without an email advising of a new penalty (so people aren't even realizing it is there).  But when you contact Google, they remove it again without having done any additional cleanup.  It is like a bug causing it to show up again when there really isn't a new penalty, and Google seems to be removing it (again) pretty quickly when notified.
Thanks for commenting John.  I have had a few cases now where the sites initially had a partial action, we did a lot of cleanup work and eventually got a "manual spam action revoked" message and the message also said, "There are no manual actions on the site."  But, the message in the spam actions viewer either never changed to show "no manual actions" or I do believe in some cases, it showed "no manual actions" and then reverted to showing a partial action again (with no new notification of a new penalty).  
This is a widespread problem and causing great distress for clients who have done the work in "good faith" and are rightly upset because messaging is all over the place.
I have multiple rmoov customers who have now contacted our support line asking for help in understanding what is going on. Among them are people who have submitted a reconsideration request and received 3 different responses in a space of 4 days! In that space of time Google has apparently: reduced the manual action from sitewide to partial (but it was always reported as a partial); Revoked the manual action and; Applied a manual action!
I also have a client who has email messaging of a manual action with no manual spam action reported in the checker, so no access to the "red button".
I'm sorry +John Mueller , this is nothing like "pretty rare". Something in the messaging is broken. While it may be a total coincidence, it actually began happening to our customers within a week of the addition of the text help field for webspam team members.
Not to jump to conclusions, but a bug is a definite possibility.
Without any examples, there's not really much I can do. These processes are constantly being analyzed and improved. Due to these requests being reviewed manually, there is a possibility of edge-cases sometimes going the wrong way (how much is "cleaned up enough"? It's sometimes hard to determine objectively), and even mistakes could happen. That's why it's useful to allow the webmaster (or you -- the experts who have worked with lots of sites on similar issues) to submit another request. It's in our own best interest to help webmasters efficiently solve problems that come up (if they're willing to do that), and there's definitely no "let's confuse webmasters" policy in place :). 

So if you have examples, you're welcome to send them my way. The webspam team takes these very seriously. That said, sometimes there's not much more that we can say to escalations, sometimes the webmaster just needs to do more to clean things up. 
Thank you +John Mueller .  I have sent my examples to the webspam team.  Hopefully they will help them to figure out what is happening.
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