Folders won't delete in XP until restart

Anyone else noticed how certain folders every now and then won't get deleted unless you either restart XP or close Explorer in the Task Manager and rerun it again? What exactly causes this and is there a fix?

workarounds :

- get a tool from micro$oft's website called "Open Command Line Here".  use this to open a command window near the offending file or folder, and delete the file using "del" or "deltree".

- get sysinternal's ProcessExplorerNt, and search the offending filename using the Find Handle function.  then select the filename/handle on the lower panel and select Close Handle.  it should be deleteable after that.