It's not usually blackhat. It's happened since 2001 at least, for at least two reasons:
1, Google simply makes a mistake in choosing the correct URL...
2, is similar to 1, but they don't really make a mistake. Suppose a cardroom has 100 websites linking to it with tracking URLs and maybe a few dozen links pointing at it to just thiscardroom.com. Now suppose one of those 100 websites has thousands of pages linking to thiscardroom.com/?1234. The search engine generally tries to find the stongest URL to list, and sometimes it could conceivably be some affiliates tracking URL.
A blackhat thing is to get the actual thiscardroom.com URL to be hijacked and a tracking URL replacing it. This seems like the same thing, but really isn't.
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