But remember, guys, the Elbow Plane is not an absolute. Some Angles are steeper than others, especially through Impact (versus Address).
Also I think, in the case of the Golden Bear, he did favour a fade. With the most vicious release he could produce as a kid. He is swinging left but the clubhead is thrown out right. That will look like a planeshift at impact.
Maybe it is but maybe it isn't. Same thing with Hogan basically, although everything was flatter with Hogan.
Does the ball REALLY just get in the way or does ball location make a difference to timing etc.... ? In any case, that's the only factor I can think of that can "justify" a late planeshift. The more speed the club picks up the harder it will become to shift plane downwards. Because of CF. But you can let it happen upwards. By just letting the clubhead drive the hands out and up. That would be the opposite of what Homer K. recommended I think, when he told us to swing the hands and not the club.
Anyways; If you (within reason) are swinging or hitting as hard as you can - can you do a late planeshift downwards? I don't think so. If the hands are low through impact there's something else going on IMO. And it probably was initiated in the transition as all good things in a full motion.