Yes, it’s possible. If certain fuse bits are set during programming this can happen. At that point only “high voltage” programming can be used, the ISP type we normally use will not work. In this thread in posts #52-61 we discuss the issue a little and I link to a “rescue programmer” project.
I don’t know if it’s done at Atmel or elsewhere, but I’m told that pre-programmed AVRs can be purchased. They’d be reeled and everything, ready for pick-and-place. Maybe what you received are excess pre-programmed ones with the situation I described above?