Yeah with primary extraction problems it should do it all the time. Primary extraction should break the case free of the chamber while moving slightly to the rear making secondary extraction easy.
Many people, when "trueing" an action, will take too much from the lugs, both in the action and on the bolt, resulting in a loss of primary extraction camming. It could be that this rifle has the lug 'looseness', but as I stated it should be showing up all the time. Hense why I suspect overpressure.
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