I just ran into this problem myself. A coworker found this site. The issue is also discussed at http://www.opensolaris.org/jive/thread.jspa?messageID=102769
They problem surfaced when I tried to install packages in a zone I had created on a zfs filesystem that happened to be on a x4500 with 15 Terabytes of free space.
The work around is to slap a quota on the the ZFS that the zone sits on.