It can get a bit sticky when current players try that, and depending on what property it is. Autos are one thing, but use of no images can ruin a set.
Shaq tried that with Classic in '92, but once the NBA series II stuff started hitting, he was in them. Had he not been, I doubt that rookie class would've looked nearly as strong, and basketball cards wouldn't have had such a surge.
'89 Hoops having David Robinson during his rookie season was a big winner for them.
'88 Maxx missing Dale Earnhardt always baffled me. I don't count the use of images of his car, or the #99 that surfaced years later.
'91 Ringlords, and '91 Kayo boxing not having base cards of Mike Tyson. Again, promos surfaced after the sets released.
'92 Football sets had some players who didn't appear at first, some deal with NFLPA vs. NFL, think it was mostly QB's. It was a bit confusing at the time, and I don't even want to try to look it up this early in the morning.
Non-sports sets can also have some missing subjects, but that's another animal entirely.
I'm sure there are many more I'll think of later, or others will mention.
"I believe there ought to be a constitutional amendment outlawing Astroturf and the designated hitter." - Crash Davis