Interesting. In the past, an external mouse (BT or USB) was required in order for a MacBook to operate in "clamshell mode". If no such device were connected, you couldn't get the laptop to turn on. Period. This makes me wonder if there isn't a firmware bug?
EDIT: An additional requirement (forgot): an external display must be attached. I'm doing some testing with my 2011 MacBook Air that is still running Lion.
CORRECTION: My MacBook Air is running Lion, not Snow Leopard. Brain fart!