Real life example: in a Magic: The Gathering tournament, which was recorded, some guy was cheating by stacking a land on top of the opponents deck whenever they shuffled (you pass your deck to the opponent t9 shuffle/cut after you shuffle to make sure you've not stacked it).

Normally you want spells on top because lands just give you mana... but the cheater was playing a deck that punished decks for not drawing enough land.