See http://forums.gentoo.org/viewtopic.php?p=605071#605071 for details. Reproducible: Always Steps to Reproduce: 1. 2. 3.
(Oops, hit the wrong key and entered that too fast. Anyway ...) In summary, "Deny from all" is failing in both the <Directory> and <Files> context. Other directives continue to work. This is on two different systems, running fairly standard Apache ebuilds. Which isn't to say I might not have something configured wrong - but as you'll see in the forum I've run through the usual suspects.
My fault. Didn't understand that <Directory> can be totally overridden by <Location> (even when Directory sets "AllowOverride None" first - odd logic here that I wasn't allowing for in diagnostic attempts, since directory permissions are at the system level on *nix systems, and are never altered at the program level - which "Location" would seem to be at).