I would say there are two aspects of clustering that are important: accuracy of the model, and accuracy of the model fitting process.<p>A model is a guess about the underlying process that "generates" the data. If you're trying to use hyperplanes to divide data that lies on a manifold, then you are going to have poor results no matter how good your fitting algorithm is.<p>On the other hand, even if you know the true model, high levels of noise can prevent you from recovering the correct parameters. For instance, Max-Cut is NP-hard, and the best we can do is a semidefinite programming approximation. Beyond a certain noise threshold, the gap between the SDP solution and the true solution becomes very large very quickly.