For others who may run across this - it can also occur if someone carelessly leaves trailing spaces from a php include file. Example:
<?php
require_once('mylib.php');
session_start();
?>
In the case above, if the mylib.php has blank spaces after its closing ?> tag, this will cause an error. This obviously can get annoying if you've included/required many files. Luckily the error tells you which file is offending.
HTH