Rare Steal always fail?

The rare steal simply has a 1/8 chance of being picked when a Steal is successful, as opposed to the common Steal, which has a 7/8 chance of being picked. Regarding the fact that the Lobo special doesn't fail, that's the point. If a perfectly viable Special still fails to Steal, then there must be a cause that isn't related to the Special attack itself. In this case, a level 39 thief in this circumstance looks to have about a 1/8 chance of having all possible RNG sequences fail against a level 77 target.