I was on showdown, and I switched Rotom-H into Terrakion, and Earthquake KO'd Rotom-H.
Smack Down, Gravity etc. were not in effect, Terrakion had Justified and Rotom-H had Levitate.
There was nothing that could have cancelled Rotom-H's Levitate, so bar Terrakion's held item (what held item even does that) or a glitch, I don't see any other way Rotom-H could have been hit with Earthquake.