In my past experiences, if you're on tor (or proxy'd through a known portal), and have Javascript disabled entirely, Google will sometimes (not always) give you an error stating that your IP is a known abuser. If you DO have JS enabled, I have encountered the "Your IP is known to be abusive, so type in this captcha in order to continue" and then it forwards to encrypted.google.com.
To be fair it's quite likely your IP has been abusive. There aren't that many exit nodes and it doesn't seem unlikely that a lot of Tor users have suspicious or malicious behavior.