This seems to me as a bug from upstream that is filtering down through
the distro's.

Using Ubuntu 10.10 LiveCD's e2fsck from the e2fsprogs package 1,41,12
failed to check an ext4 disk with errors saying the aforementioned
error.

Using a systemrescuecd-x86-2.1.0 CD's e2fsck from the e2fsprogs package
1.41.14 failed to check an ext4 disk with errors saying the
aforementioned error.

Using a Slax 6.1.2 CD's e2fsck from the e2fsprogs package 1.41.3 (2008)
checked and fixed an ext4 disk with errors.

Even though the Slax CD could not mount or do anything with the partition as it 
does not have ext4 support.
Go figure.

This leads me to think that this has not been fixed

E2fsprogs 1.41.13 (December 13, 2010) states:
"Fixed a bug in e2fsck where if both the original and backup superblock are 
invalid in some way, e2fsck will fail going back to the original superblock 
because it didn't close the backup superblock first, and the exclusive open 
prevented the file system from being reopened."

Unless Gentoo's e2fsprogs 1.41.14 missed this patch??

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https://bugs.launchpad.net/bugs/711799

Title:
  e2fsprogs wrongly identifies ext4 as mounted

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