An interesting Google Webmaster Help thread has a webmaster who has a manual action, he said he removed the content, and even left the page blank but the manual action won't go away.
Google's John Mueller explained why in an interesting way. He wrote:
If there's no content on these pages, there's nothing that users would be missing by lifting a manual action. If you'd like your reconsideration request to be processed, you really need to first have unique, compelling, and high-quality content of your own on these pages (not just rewritten, spun, autogenerated, or otherwise reused content).
You see, he said "if there's no content on these pages, there's nothing that users would be missing by lifting a manual action."
That is true, but if the manual action was for the content, then if it is gone - shouldn't it be removed. That is an assumption that here the penalty is for content.
Anyway, I wanted to share this with you all because the response was pretty interesting.
Forum discussion at Google Webmaster Help.