We were all sitting around at the user group and decided to reply.  By increasing past the 32 limit it's really just working around the issue, there is more than likely something going on locally at the users workstation.  It may be worth having some of the effected users launch Outlook in safe mode i.e. outlook.exe /safe and see if still occurs.  

Additionally any desktop search tools (windows search 3.0, Google desktop search... etc.) searching against the online mailbox will increase the connection count as well.  these clients should be placed in cached mode if they arnt already. 

After review of the logs, we determined that <50 users (out of thousands) had exceeded 32 connections, so we decided to disable the session limit.

This requires a registry update on the Mailbox Server, and restart of the Information Store service.

[HKEY_LOCAL_MACHINE\SYSTEM\CurrentControlSet\Services\MSExchangeIS\ParametersSystem]
"Disable Session Limit"=dword:00000001

After the update, we haven't had the 9646 32 connection errors, but some users had >100 connections at times. The errors appear to be the related to the Windows XP client patch level, and possibly NIC/Wifi driver version.

Reference Link
MAPI Session Limit Disabled
http://technet.microsoft.com/en-us/library/dd159906(EXCHG.80).aspx