I think it depends on the circumstances. Let's say that someone has started their studies at a crappy private school or university and then realizes it's a crap school and leaves. Let's say they are now applying to attend a good public university or college program. In that case I think an argument can be made that their first choice of programs and schools wasn't strong. But it of course depends on the details - what program and school they are in now, what program and school they are switching to, and why. If they are currently in a master's program and looking to drop down to a lower level of studies, that will be a more difficult argument to make.