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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 but I've seen it happen remotely with svn+ssh as well.
Here's an example of this coming up recently:
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Deleting (sub dir) svn: Commit failed (details follow): svn: Out of date: '(some path)/(old dir)/(sub dir)' in transaction x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?
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You can fix the problem by running 'svn update' in the working copy. You might be genuinely out of date - that is, you're trying to commit a change to a file that has been changed by someone else since you last updated your copy of that file. Again, 'svn update' is the way to fix this.
Examples. Use the svn upgrade command to upgrade the working copy to the most recent metadata format supported by your version of Subversion.
An svn commit of the file will fail with an “out-of-date” error. The file should be updated first; an svn update command will attempt to merge the public changes with the local changes. If Subversion can't complete the merge in a plausible way automatically, it leaves it to the user to resolve the conflict.
To view or break locks, right-click in the Current Folder browser and select Source Control > Locks. If you see an SVN message reporting a working copy locked error, remove stale locks. In the Current Folder browser, right-click and select Source Control > SVN Cleanup.
Check out the SVN FAQ entry on this issue. I believe you are genuinely out of date and just need to run "svn update".
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