The phone had been sitting idle (screen off) for a while and I didn't have anything actively running.
Either way, this really shouldn't be a problem. Any flash memory device that "runs out of batteries" is supposed to hold a small charge to make sure the flash memory does not get corrupted in this way. I don't think it should be user error for a phone to run out of batteries with an unknown process running in the background, forcing a full SD card format.
If nobody else has had this issue when the battery runs dry I am going to test it again tonight. If the same problem occurs I will consider it an issue with the phone and/or SD card and take it back.
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