They could be those people who look fabulous on paper, but in person, they fall completely flat, smell funny, or are painfully awkward. I find that the smarter the group of people, the more likely there's going to at least one person like that in it.
Or, coming from the T14, they could be people who only want to work in a niche market or terribly competitive field, and are still looking and waiting for the perfect job.
OR maybe they had jobs contingent on passing the bar and failed - it is NY and CA after all.
Although, I have to say, 3 people out of an entire class at Columbia or Berkeley out of work isn't bad.