There exist funds which have annualized a two-sigma return over SPY for over 20 years. If you model returns as approximating a normal distribution (e.g. just luck), and you model years achieving a return at least two standard deviations above the mean under a binomial distribution (i.e. number of years they've been exceptionally lucky), the likelihood of those track records existing are around 1 x 10^-37.
I would call that sufficient evidence to reject the null hypothesis that the returns are normally distributed, which is to say it's not luck. If you expand your sample size to all investment vehicles throughout history, there still haven't been anywhere nearly enough for such a track record to emerge by chance.
Elementary statistics is well equipped to distinguish between a distribution signifying luck and a distribution signifying skill. It's structurally the same as assessing normality, noise, randomness, etc.