missing-root I imagine a factory reset is handled by firmware, tho the operating system does have to call a factory reset
Regardless, I don't think Google Play services or carrier software could effect this, since factory resets are done either in recovery or after a restart (which would most likely disable most of these applications)
Even then, the weaver would be lost, memory would be cleared, so what would they really be able to do? The data by all accounts is gone as soon as that weaver is dropped (and memory is flushed) and that's done on a firmware level
Not to mention the user data is then marked as free, meaning its free game for overwriting, which would further harm the possibility of a 'fake factory reset'