KB Article: http://support.microsoft.com/kb/2025703

INTRODUCTION

Steps to reproduce the issue:

1.Map a drive to a network share that contains several sub-folders that contains images files or PDFs

2.Open an Explorer window and navigate to the parent folder.

3.Attempt to rename each folder successively, while drilling into the sub-folder contents.

4.Continue step 3 until an error dialog containing the following text appears indicating that the sub-folder cannot be renamed:

"The action can't be completed because the folder or a file in it is open in another program. Close the file or folder and try again."