Scott, I am working on HHH-8996 which claims we are being overly aggressive in one cases in terms of marking a transaction for rollback only stemming from this issue.

Specifically a call to EntityManager#createNamedQuery(String). This change reverted a previous fix to not mark the transaction for rollback only when this situation happens; the previous fix did not include a test case unfortunately which is why we did not see it.

Anyway, can you point out the section in the spec where it says that calling EntityManager#createNamedQuery(String) where that name is not known is supposed to result in the transaction being marked for rollback?