I agree that setRollbackOnly is the most safest action, as it ensures that the application will know that the transaction failed. If Hibernate only threw an exception, the transaction manager might eat the exception or it might not. I was just curious if it makes a difference in the reported use case. I'm guessing that WebLogic might report a different problem as the root issue, that is closer to the database constraint violation than weblogic.transaction.internal.AppSetRollbackOnlyException but I'm only guessing.