In the past few years of using svn, I've frequently run into problems where commits would fail with the above error. I originally thought this had to do with the use of samba mounted work spaces and some but I've seen it happen remotely with svn+ssh as well.
Here's an example of this coming up recently:
- Rename a directory using svn move
- Commit change to new directory
Try to commit deletion of old directory -- fails with:
Deleting (sub dir) svn: Commit failed (details follow): svn: Out of date: '(some path)/(old dir)/(sub dir)' in transaction x
Addition: What is the best way fixing these problems when they do occur?