If you include their costs and fees, that is not the case though is it? Or at least the data I've been able to find doesn't support that.
You're also talking about rearward looking data, not forward looking predictability, often only including hedge funds for instance that still exist today. For any given hedgefund who outperformed in the past, how likely is it that, if you made a judgement today on their ability to perform, and then waited 1, 5, 10 years in the future, it would match that judgement? What are the odds they'll exist then, or be merged or renamed or whatever?
If you today made a bet for 10 years from now as to Steph Curry's 3 point average then, how likely would it be to win?
There is a reason anything to do with the markets is almost always followed with 'past performance is no guarantee of future results'.
There are also confounding effects like the Bernie Madoff's and Enron's of the world, and major issues with visibility into most hedge funds that make it difficult to actually compared performance on a level playing field. If someone is 'loading the die' using insider trading, tips from the CIA or whatever, it would be really difficult to call them anything but incredibly skilled/lucky - and you couldn't tell the difference unless it blew up publicly.