I'm piggy backing on Josh's comment above, or the leads have emails that forwards to another email, this is a big one for us. Another way that people have received emails from us even though they are marked unsubscribed in SFDC is if they are using another email tool other than Marketo. In our case our events department still uses CVENT to deliver emails (this I don't like), and there are other people in our company who are sending emails through their own work email address (without looking at the email opt-out type in SFDC, another bummer).