Okay, that's what I figured. This was the first I had ever had this type of error reported to me, and it happened so coincidentally with the upgrade to 8.1 that I thought it might be related to that. I'll have to check in with the user to see who the messages were received from and confirm that it was or wasn't user error causing this "issue (see the message details and match that to my logs to see when the message was actually received by my server).
If you can get the full headers from the user, you can probably figure out where the issue lies. If you compare the top Received: header (that your mailserver added) to the previous Received: header (the one that the remote mailserver added) and find that they are nearly identical (aside from different time zones), and the Date: header is many hours off, then the problem is almost certainly an issue with the sender's mail client.
-Scott
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