It was a huge pain for me. Was considering going to an Apple store to get it fixed. I did the full "recalibration" technique, and I haven't had issues since then.
Granted, this is anecdotal. But at least for me, it did the trick. I have a iPhone 4 iOS 4.2.6, if that helps.
My 4g ipod touch has this problem; regretfully, my warranty expired before I could do anything about it.