The bare fact that certain funds or managers have averaged 20%+ over whatever time period is irrelevant, as that is absolutely expected due to randomness alone. It has no predictive power over the ability of those funds to generate future alpha, regardless of what intuition suggests. Again, in other words, investing in a fund that has consistently outperformed in the past does not increase your expectation of outperforming in the future. In fact, it is more likely than not that you will still underperform a low-cost passive fund with the same factor exposure.
So…you're saying that Bayesian updating in this case does not apply? No amount of positive results should alter the probabilities…ever?
(I'm not challenging your assertion by the way, just trying to confirm for myself.)
The paper demonstrates this by comparing the actual distribution of returns to many sets of simulated returns over the same period. When the simulations are built assuming that fund managers have just enough skill to generate zero net alpha, the actual distribution has consistently lower returns across the board than the majority of the simulated distributions. It gets closer in the very extreme right tail (the 98th to 100th percentiles), but still not enough to generate positive four-factor alpha net of fees.
The paper you linked by Fama and French doesn't support this assertion. In fact, it's incorrect, and the paper admits that there are outliers (however few) with consistent superior performance.
From 1994 to 2014, Renaissance Technologies averaged a 71% return. From 1982 to 2012, Baupost averaged a 19% return. In the same time period the S&P 500 returned 7-8%. Even after fees, these managers easily beat the average for their clients.
It's tempting to claim that there is no such thing as beating the market, especially if that belief aligns well with a corresponding set of political beliefs about Wall St. But it is inarguable that funds and managers like these exist, it's just a matter of admitting that it's extraordinarily difficult instead of impossible.