Phony study on phony web sites

The Si Valley paper reports:

With a little sleight of hand, con artists can dupe them into giving top billing to fraudulent Web sites that prey on consumers, making unwitting accomplices of companies such as Google, Yahoo and Microsoft. ...

Stickley created a Web site purporting to belong to the Credit Union of Southern California, a real business that agreed to be part of the experiment. He then used his knowledge of how search engines rank Web sites to achieve something that shocked him: His phony site got a No. 2 ranking on Yahoo's search engine and landed in the top slot on Microsoft's Bing, ahead of even the credit union's real site.

Con artists can show up in searches, but this does not prove it. The researcher created an authorized site that directed customers to what they wanted. It was not a fraudulent site. So why should a search engine block it?