Copy List Item in SPD 2010 Workflow Fails if Check Out/Check In Required

I've seen this issue on 3 different Sharepoint 2010 implementations, including upgrades and fresh installations...

The workflow, which works fine in WSS 3.0/MOSS, operates on change of a document.  Workflow reviews a specific column and based on contents of that column, it checks out the document, copies the current item from the current library to another library in the same site and then deletes the item in the current library.

In SharePoint 2010, the following occurs.  Again, this occurs in the upgraded workflow as well as in a brand new workflow created with SPD 2010 on a site that blank / not upgraded.

• Workflow starts on an item that is verified to not already be checked out.
• Document is checked out
• Document IS copied to the other library
• Workflow fails and is canceled with the following errors:
  The workflow could not copy the item. Make sure the source and destination lists have the same columns and column settings.  (They do.)
  The workflow operation failed because the action requires the document to be checked out. (The item is checked out by workflow - as is evidenced by the fact that the item is still checked out after workflow fails.)
• RESULT:  the copy operation does work, workflow thinks it doesn't and fails on that step, item is not deleted

I've tested this enough and on enough sites that i'm thinking this is a bug.  As such, I've tried this on a sharepoint 2010 implementation with the August 2010 cumulative update applied.  That didn't fix it.

Any help with this will be greatly appreciated. 

Thanks!