Hello,
For an issue like this where it is such a small percent it is possible that a few messages are taking a different route and some how being modified ( gateway, spam filter, etc... ) along the way. It you are able to get a copy of the message from any clients that are showing this issue we could parse the header vs a good message and see.
Tony Scholz
System/Network Administrator
SmarterTools Inc.
www.smartertools.com