Exactly, well, not exactly, but I'd give it a >95% correlation that X on
fgconsole when rmmod e1000 is typed will cause a panic shortly
thereafter, noting that the rmmod itself does complete successfully and
exits, it's a short time afterwards (long enough for the suspend scripts
to chvt typically) that the panic occurs.  The chvt does not have to
happen to cause a panic, but it can be acheived. My first workaround was
in fact just to change vts earlier in the suspend process.  Someone
seemed to indicate they at least once managed to suspend even without a
workaround, so it might not be 100%.

I have not seen the panic at all myself after rmmod e1000 if the current
VT is text.

See my third comment near the beginning.

-- 
IBM T41,42 Regression: Kernel Panic for Suspend/Hibernate
https://launchpad.net/bugs/62196

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