Google impose manual penalty on websites which violate the webmaster quality guidelines. The manual action were increased by Google Penguin updates. Whenever there is manual action against any website it is clearly visible in Google webmaster Tools. Website owner remove the bad links or spam activities and then apply for reconsideration request. After two or three attempt most of website get out of manual penalty. In some cases you can upload the disavow files for bad links which you are unable to remove if carry all links removal activities.
There are case which Google had noted that some website after getting out of manual penalty again start spam activities or do not follow quality guidelines. Google issued a warning on its webmaster blog that if there will be repetitive violation of quality guidelines Google may not consider reconsideration request. Google advised webmaster not do it again and again
Pedro Dias, former Google spam fighter, said on Google+
I have mixed feelings about this “repeated violations” post. I feel it was unnecessary; it doesn’t really benefit anyone. People who engage in that kind of behaviour don’t really care about this info; plus it puts Google under a “punisher” light instead of a “guide”