I have a Droid and a couple of bluetooths (Motorola H721 and H730). The behavior is the same with each so I'm sure the phone is the culprit.
Before the OS upgrade I did yesterday, if the Bluetooth was connected for more than a few miniutes it would take at least two to four presses of the button to get the Bluetooth to ask for a command while in the holster.
The phone would also drops the Bluetooth connection intermitantly and then reconnect which was a pain if it happened during a call. This would happen in or out of the holster.
After the upgrade if the Bluetooth is connected for more than a few minutes, I press the button and it starts the command but hangs up in the middle of the voice prompt until I take it out of the holster, then it works, but not a legal move while driving.
The holster may be the issue, but its one they sold me when I got the phone at my local verizon store. If I turn the phone screen out in the holster, the problem doesn't happen. The Holster has a rotating clip on it with a weave pattern, there is no brand name ot it or the shell that came with it.