Welp, I hate to be the bearer of bad news, but someone's modded in a Mallow Mii hat with jiggle physics. So it is possible. Damn.
I suppose the leak isn't technically 100% dead, but I've been nudged over to "most likely fake" (though at least partially to save myself from getting Grinch'd again).
Not that Geno's chances are affected, but those Miis looked so clean..