Some people who don't think they need micromanagement actually do. The problem is they keep diverting and working on something else, and need to be continually reset back on to the critical path. A good manager will adapt to what works best for the particular employee.

It'll take some time, though, for a manager to learn that a particular person can be trusted with a hands-off style. I've tended to default to hands-off as a manager, sometimes with expensive results.