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After setting the spatial filter of an SeQuery using the SeQuery.setSpatialConstraints() method, a subsequent call to SeQuery.execute() throws either a "numofpts is less than required for feature" or a "Polygon does not close properly" error. This problem only occurs when using multipart polygons or lines as filters to the query.
This is a known issue in the ArcSDE 8.1 Java application programming interface (API).
There is no work-around for this issue.