Actually,

as a follow up, it seems that my output method is what's misleading me. 
I've changed some things up to display different and I am seeing the error
messages returning an array with the subForm title being listed (as I would
have expected it to).

So, it seems there's something else going on that I'm not catching properly. 
Like, where this number "1" is coming from.  But, regardless,
$form->getMessages() is returning an array, it just wasn't being output
properly.
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