Although in most general cases the error is quite clearly that file handles have not been closed, I just encountered an instance with JDK7 on Linux that well... is sufficiently ****ed up to explain here.
The program opened a FileOutputStream (fos), a BufferedOutputStream (bos) and a DataOutputStream (dos). After writing to the dataoutputstream, the dos was closed and I thought everything went fine.
Internally however, the dos, tried to flush the bos, which returned a Disk Full error. That exception was eaten by the DataOutputStream, and as a consequence the underlying bos was not closed, hence the fos was still open.
At a later stage that file was then renamed from (something with a .tmp) to its real name. Thereby, the java file descriptor trackers lost track of the original .tmp, yet it was still open !
To solve this, I had to first flush the DataOutputStream myself, retrieve the IOException and close the FileOutputStream myself.
I hope this helps someone.