Ok this seems to be a bug unfortunately:
http://code.google.com/p/android/issues/detail?id=4255#c2

On Nov 14, 2:47 pm, Mark Wyszomierski <[email protected]> wrote:
> Brady, did you come up with a work around for this? I'm having the
> same problem, and I can't come up with some sort of temporary fix for
> it sadly.
>
> On Oct 14, 5:10 pm, Brady <[email protected]> wrote:
>
>
>
> > Ok, I did some more sleuthing and this is definitely a bug.
>
> > I modified the 1.5 SDK API demo Views > Lists > ex 7 to test. I added
> > a button above the listview in the  list_7.xml layout. The same
> > problem occurred on my 1.6 Donut Ion. If I set focus to the button
> > using the 5-way nav, then nav down, the focus jumps to the 6th item in
> > the list of contacts. Somewhere in the code a setSelection(5) is being
> > called.
>
> > Gonna file a bug.
>
> > Brady

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