Hmm, well I'm a little puzzled then - as far as I can tell the upgrade totally 
solved my problem! I did post to the hibernate forum (see 
http://forum.hibernate.org/viewtopic.php?t=958651).

emmanual wrote
anonymous wrote : 
  | so be sure to use Seam 1.0.0 CR1 or 2
  | It comes bundled with Hibernate EntityMaanger 3.1 beta7 which fix this issue
  | 

Perhaps he wasn't talking about my workaround issue (the session flushMode 
resetting) - but the original validation issue? I'm not sure if my Hibernate 
post was all that clear.

Would the validation tags (temporarily at least) replace the need for the 
@Valid and @IfInvalid annotations?

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http://www.jboss.com/index.html?module=bb&op=viewtopic&p=3939908#3939908

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