Sorry to answer my question so quickly, but I just found the problem.
If you return NO for the delegate method:
- (BOOL)webView:(UIWebView *)webView shouldStartLoadWithRequest:(NSURLRequest *)request navigationType:(UIWebViewNavigationType)navigationType;
and then release the UIWebView, it will leak as described above. Return YES resolves the issue. At least for me, this happens in all versions of the firmware to date (4.3.3). I am logging a bug with Apple.
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