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The pane that displays a field API field can force the #title of the field to override with the pane title in the default configuration. However, in doing so, it doesn't check to see if the field output was NULL, and this can cause drupal_render() to actually render an empty pane, which is wrong behavior.
This report comes from http://drupal.org/node/1025716#comment-6350806 and is properly its own issue.
The patch is quite simple, and forthcoming.