They were just talking about this on the Postfix list today, as well. Wietse Venema is the developer of Postfix. Attached is a question regarding the Message ID, and his response. Interesting that this issue came up on both lists today.
[Message from the Postfix list:]
> The Message-ID header is not required.
Just to elaborate here: The Message-ID: header is not required. However, the RFCs state that it "SHOULD" be there. In RFC terminology, that means that it *must* be there unless there is a good reason for it not to be there, *and* the developer is willing to accept the consequences. In short, this means that the developers of such mail clients were lazy (typically they were written by web developers that know web programming very well, but know nothing about writing mail clients).
-Scott
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