Well, I mean not actively maximizing your CV score, just accepting normally insufficient CV scores.
For example, in a tree based regression with a very small number of training samples, the leaves will almost resemble some of the training samples. A good generalization might not be possible at all. But this is not too bad if you know that your prediction samples have high similarity with at least one of the training samples. In the end, this is an edge case for Machine Learning but goes more into the direction of Expert Systems.