I believe I have a repro of this bug here: http://jsfiddle.net/joshma/t68Nv/5/
I ran into it when my child component called a passed-in handler to clean up during its componentWillUnmount, triggered while the parent was unmounting as well. This handler, belonging to the parent, tries to pause the parent's audio node, but this.refs.audioNode was already empty. (For what it's worth, when I inserted a breakpoint the DOM node is still there.)
I mentioned this on IRC and @zpao suggested it might be a bug, so here I am. :)