CVE 2005-4351
The securelevels implementation in FreeBSD 7.0 and earlier, OpenBSD up to 3.8, DragonFly up to 1.2, and Linux up to 2.6.15 allows root users to bypass immutable settings for files by mounting another filesystem that masks the immutable files while the system is running.
See the 
CVE page on Mitre.org
for more details.
