I'm not sure if you've seen them, but there are LED glow sticks that look normal when stationary but leave sort of a trail of distinct after images rather than a smooth blur when waved. I've seen LED Christmas lights that have a similar effect when you scan your eyes past them quickly. It's called the phantom array effect, and it's caused by a flickering light (LEDs lit with less than 100% duty cycle) moving rapidly across the visual field.

Mitigating sample and hold motion blur by blacking out the display for some of the frame time turns your display into a flickering light source, so it can potentially produce the same effect for small bright objects on dark backgrounds when either the object moves rapidly on screen or you scan your eyes across the screen. It's fairly niche in that it'd only affect some rather specific scenes and even then can depend on how the scene is viewed (it won't occur if you track the only fast-moving bright object with your eyes, and it's much reduced in higher ambient light), but the flicker fusion rate is generally several kilohertz, so you'd need to boost the hell out of the frame rate to guarantee the effect is eliminated altogether.

More generally, an object that is moving rapidly enough for its screen position to change by many pixels per frame can have its motion look jerky even without motion blur. And, in fact, motion blur can help disguise that.