Cannot delete directory after crash

Greetings,
  This is just to report a problem I had recently with FreeBSD 5-CURRENT 
(from a couple of weeks ago) with a full filesystem.  The box first froze 
due to an FS being full for an extended period of time (I've seen it happen 
before with 4.x as well).  After having the box rebooted, it came back up 
and I started clearing out some space on it.  What I did not realize until 
later was that fsck -B was running on that filesystem.  This caused rm to 
obviously have no effect since there was an active snapshot of the 
filesystem.  Free space remained about the same.

  The main problem I encountered though was that there were some 
directories that i could not delete.  rm -rf would constantly return an 
error saying that the directory was not empty.  After running fsck -fy on 
it, the problem appears to have gone away.  I have a theory on why I think 
this happened though...

  I think that the snapshot code was trying to write data to a filled disk 
(copy on write) while I was deleting a bunch of files and fsck was running. 
This is my theory on why softupdates was unable to do its job properly.  I 
can't confirm that, but I think it might be something worth looking into. 
Is the snapshot code smart enough to deal with that situation?

Let me know if this makes any sense.  I am also off list, so please CC me 
in any replies.

Thanks in advance!
-JD-